In 2014: The US is an oligarchy, study concludes

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(Researchers concluded that US government policies rarely align with the the preferences of the majority of Americans Photo: Bloomberg)

The US is an oligarchy, study concludes
Report by researchers from Princeton and Northwestern universities suggests that US political system serves special interest organisations, instead of voters
The Capitol building in Washington DC

By Zachary Davies Boren
10:58AM BST 16 Apr 2014

The US government does not represent the interests of the majority of the country’s citizens, but is instead ruled by those of the rich and powerful, a new study from Princeton and Northwestern Universities has concluded.

The report, entitled Testing Theories of American Politics: Elites, Interest Groups, and Average Citizens, used extensive policy data collected from between the years of 1981 and 2002 to empirically determine the state of the US political system.

After sifting through nearly 1,800 US policies enacted in that period and comparing them to the expressed preferences of average Americans (50th percentile of income), affluent Americans (90th percentile) and large special interests groups, researchers concluded that the United States is dominated by its economic elite.

The peer-reviewed study, which will be taught at these universities in September, says: “The central point that emerges from our research is that economic elites and organised groups representing business interests have substantial independent impacts on US government policy, while mass-based interest groups and average citizens have little or no independent influence.”

Researchers concluded that US government policies rarely align with the the preferences of the majority of Americans, but do favour special interests and lobbying organisations: “When a majority of citizens disagrees with economic elites and/or with organised interests, they generally lose. Moreover, because of the strong status quo bias built into the US political system, even when fairly large majorities of Americans favour policy change, they generally do not get it.”

The positions of powerful interest groups are “not substantially correlated with the preferences of average citizens”, but the politics of average Americans and affluent Americans sometimes does overlap. This is merely a coincidence, the report says, with the the interests of the average American being served almost exclusively when it also serves those of the richest 10 per cent.

The theory of “biased pluralism” that the Princeton and Northwestern researchers believe the US system fits holds that policy outcomes “tend to tilt towards the wishes of corporations and business and professional associations.”

The study comes in the wake of McCutcheon v. Federal Election Commission, a controversial Supreme Court decision which allows wealthy donors to contribute to an unlimited number of political campaigns.

President Donald Trump’s tweet Sunday morning advising left-wing members of Congress to “go back and help fix the totally broken and crime infested places from which they came.”

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(US President Donald Trump smiles as US Secretary of the Interior Ryan Zinke looks on during the 95th annual National Christmas Tree Lighting ceremony at the Ellipse in President’s Park near the White House in Washington, DC on November 30, 2017. / AFP PHOTO / NICHOLAS KAMM (Photo credit should …
NICHOLAS KAMM/AFP/Getty Images)

Democrat 2020 Candidates Pounce on Trump ‘Go Back’ Tweet: ‘Un-American’
https://www.breitbart.com/2020-election/2019/07/14/democrat-candidates-pounce-on-trump-go-back-tweet-un-american/
Joel B. Pollak14 Jul 2019

Go to the link above to listen to the whole story.

Nearly every single candidate for the Democratic Party presidential nomination in 2020 criticized President Donald Trump’s tweet Sunday morning advising left-wing members of Congress to “go back and help fix the totally broken and crime infested places from which they came.”

From Lawzilla: RAINN GAUNA v. JPMORGAN CHASE BANK

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RAINN GAUNA v. JPMORGAN CHASE BANK

RAINN GAUNA v. JPMORGAN CHASE BANK

Filed 3/6/19 Gauna v. JPMorgan Chase Bank, N.A. CA3

NOT TO BE PUBLISHED

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

THIRD APPELLATE DISTRICT

(Nevada)

—-

RAINN GAUNA,

Plaintiff and Appellant,

v.

JPMORGAN CHASE BANK, N.A., et al.,

Defendants and Respondents.

C078490

(Super. Ct. No. CU13-079937)

Rainn Gauna sued JPMorgan Chase Bank, National Association (JPMorgan Chase), Chase Home Finance, LLC (Chase Home Finance), California Reconveyance Corporation (CRC) and Deutsche Bank National Trust Company as trustee of Long Beach Mortgage Loan Trust 2005-1 (Deutsche Bank) after her property was sold at a nonjudicial foreclosure sale. The trial court sustained defendants’ demurrer to all causes of action in a first amended complaint without leave to amend.

Gauna now contends the trial court erred in (1) taking judicial notice of hearsay and disputed facts, (2) ruling that her fraud and deceit cause of action is time-barred, (3) concluding that the first amended complaint does not state a cause of action for breach of contract and that her breach of contract claim is time-barred, (4) ruling that she lacked standing to challenge the assignment of the deed of trust and that tender is required to state a cause of action for wrongful foreclosure, (5) sustaining the demurrer to her causes of action for cancellation of instruments, slander of title and violation of Business and Professions Code section 17200 et seq., (6) denying her leave to amend, and (7) hearing defendants’ demurrer before her discovery motions.

We will reverse the judgment as to the wrongful foreclosure cause of action, a portion of the cancellation of instruments cause of action, and a portion of the slander of title cause of action. Based on the well-pleaded allegations in the first amended complaint, which we must accept as true at this stage of the lawsuit, JPMorgan Chase could not assign the deed of trust because it did not have an interest in the note and deed of trust. In all other respects we will affirm the judgment.

BACKGROUND

Gauna’s first amended complaint alleged the following:

Pursuant to a note secured by a deed of trust, Gauna promised to pay Long Beach Mortgage Company (LBMC) $168,800 plus interest. LBMC’s loan to Gauna was not funded by LBMC, it was funded by investors who bought certificates to the Long Beach Mortgage Loan Trust 2005-1 (LBM Trust).

Gauna signed a deed of trust in relation to real property located in Nevada County (the property). The deed of trust identified Gauna as the borrower and LBMC as the lender and trustee. It secured to LBMC repayment of the note. Through the deed of trust, Gauna irrevocably granted to LBMC the property, in trust, with power of sale. The deed of trust provided that the note and deed of trust could be sold without prior notice to Gauna. It further provided that the lender may appoint a successor trustee who shall succeed to all title, powers and duties of the original trustee.

Washington Mutual Bank (WaMu) was the original servicer on the loan. It became the successor in interest to LBMC’s assets when LBMC closed its operations. However, Gauna’s note and deed of trust were sold before LBMC closed and WaMu did not acquire Gauna’s note as part of LBMC’s assets. The Federal Deposit Insurance Corporation (FDIC) took over WaMu’s operations in 2008. JPMorgan Chase bought certain assets of WaMu from the FDIC, but it did not buy any interest in Gauna’s note.

A process to modify Gauna’s loan was started in August 2008. Gauna did not miss a payment on her loan until March 2009, when a JPMorgan Chase branch representative was unable to process her monthly payment. A JPMorgan Chase branch representative also could not process Gauna’s April 2009 payment.

On or about May 1, 2009, Gauna received a Trial Period Plan (TPP) offer which outlined the steps she should take to obtain a loan modification, including making three monthly payments of $1,034. The cover letter for the offer was from WaMu which purportedly was “becoming Chase.” The offer identified JPMorgan Chase as the lender. The offer promised to modify Gauna’s adjustable interest rate loan if Gauna timely made TPP payments and if she qualified under the federal Home Affordable Modification Program (HAMP). Gauna accepted the TPP offer. She made TPP payments in May, June and July 2009.

At some point, Chase Home Finance serviced Gauna’s loan. A Chase Home Finance representative instructed Gauna to continue making TPP payments until she received a loan modification agreement. Gauna made TPP payments during the period August 2009 through January 2010. In January 2010, Gauna was instructed to stop making further payments until a loan modification agreement was executed. She attempted to make payments in February and March 2010, but those payments were refused.

Gauna received a loan modification agreement on March 18, 2010, with instructions to sign and return the agreement within seven days. The agreement did not account for $10,340 in TPP payments Gauna had made. It increased the principal balance on Gauna’s loan from $168,800 to $172,063.08. It contained undefined terms and terms Gauna opposed.

Gauna sought clarification about the role of Chase Home Finance and asked about the identity of the lender. She spoke with several Chase Home Finance representatives about terms in the loan modification agreement and the non-credited TPP payments. Chase Home Finance representatives refused to explain terms. They intimidated Gauna into signing the agreement by threatening to deny modification altogether. Gauna signed the agreement but wrote on it, “I am requesting an appraisal and an extension; I am signing with great stress and pressure with unanswered questions. Also your window of response is unreasonable.”

Chase Home Finance refused to execute the loan modification agreement. It required Gauna to go through the modification process again. And it instructed Gauna to stop making payments to requalify for a loan modification. After making her April, May and June 2010 payments, Gauna did not make a July 2010 payment upon the instruction of a JPMorgan Chase representative. She sent her completed loan modification application to JPMorgan Chase. And she made a modified loan payment in August 2010.

In December 2010, CRC recorded an assignment of the deed of trust in Nevada County. The assignment said JPMorgan Chase assigned to Deutsche Bank, as trustee of the LBM Trust, Gauna’s note and deed of trust. The LBM Trust was closed at the time of the assignment.

CRC also recorded a substitution of trustee. The person who signed the substitution purportedly signed it as an officer of JPMorgan Chase, as attorney in fact for Deutsche Bank, in its capacity as trustee of the LBM Trust. The document said Deutsche Bank substituted CRC as the trustee of Gauna’s deed of trust.

CRC also executed and recorded a notice of default stating that Gauna was in default by $23,358.34 as of December 22, 2010. CRC then executed a notice of trustee’s sale which was recorded in Nevada County.

Gauna filed a petition for bankruptcy under Chapter 13 of the Bankruptcy Code about a month later. The bankruptcy action was dismissed.

Almost 11 months after the termination of the bankruptcy action, CRC recorded another notice of trustee’s sale. CRC recorded three more notices of trustee’s sale in 2013. It ultimately conducted a trustee’s sale in September 2013. And it recorded a trustee’s deed upon sale, transferring all of its right, title and interest in the property to Deutsche Bank, as trustee of the LBM Trust.

Five days later, Gauna filed a complaint against JPMorgan Chase, Chase Home Finance, CRC and Deutsche Bank. The trial court sustained defendants’ demurrer in part with leave to amend and in part without leave to amend.

Gauna filed a first amended complaint, alleging fraud and deceit, breach of contract, cancellation of instruments, wrongful foreclosure, slander of title, violation of Business and Professions Code section 17200 et seq., and conversion. Defendants also demurred to that pleading. The trial court sustained the demurrer to all causes of action without leave to amend. It denied Gauna’s motion for reconsideration and dismissed the action. Because Gauna’s appellate opening brief does not address the trial court’s order sustaining the demurrer to the conversion cause of action, we will not address the propriety of a demurrer as to that cause of action.

STANDARD OF REVIEW

A demurrer tests the legal sufficiency of the challenged pleading. (Milligan v. Golden Gate Bridge Highway & Transportation Dist. (2004) 120 Cal.App.4th 1, 5.) We independently evaluate the pleading, construing it liberally, giving it a reasonable interpretation, reading it as a whole, and viewing its parts in context. (Id. at pp. 5-6.) We assume the truth of all material facts properly pleaded or implied and consider judicially noticed matter, but we do not assume the truth of contentions, deductions or conclusions of law. (Schifando v. City of Los Angeles (2003) 31 Cal.4th 1074, 1081; Aubry v. Tri-City Hospital Dist. (1992) 2 Cal.4th 962, 966-967.) We also disregard those allegations in the pleading which contradict judicially noticed facts. (Intengan v. BAC Home Loans Servicing LP (2013) 214 Cal.App.4th 1047, 1054.) Viewing matters through this prism, we determine de novo whether the factual allegations of the challenged pleading are adequate to state a cause of action under any legal theory. (Milligan, at p. 6.) We will affirm the judgment if proper on any grounds stated in the demurrer, whether or not the trial court acted on that ground. (Carman v. Alvord (1982) 31 Cal.3d 318, 324.) The appellant bears the burden of demonstrating that the demurrer was sustained erroneously. (Friends of Shingle Springs Interchange, Inc. v. County of El Dorado (2011) 200 Cal.App.4th 1470, 1485.)

DISCUSSION

I

Gauna argues the trial court erred in taking judicial notice of hearsay and disputed facts. We review a trial court’s ruling on a request for judicial notice for abuse of discretion. (Fontenot v. Wells Fargo Bank, N.A. (2011) 198 Cal.App.4th 256, 264, disapproved on another ground in Yvanova v. New Century Mortgage Corp. (2016) 62 Cal.4th 919, 939, fn. 13 (Yvanova).)

Gauna asserts the trial court took judicial notice of a “private agreement pulled from a website.” Her claim is forfeited because she does not cite the portion of the record supporting it. (Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246.) Gauna further claims the trial court took judicial notice of disputed facts contained in the notice of default. Again, however, she does not cite the portion of the record in which the trial court took judicial notice of the facts she describes. We are not required to examine such an undeveloped claim. (Maral v. City of Live Oak (2013) 221 Cal.App.4th 975, 984.) The claim is forfeited. (Nwosu, at p. 1246.)

II

Gauna next contends the trial court erred in ruling that her fraud and deceit cause of action is time-barred.

While Gauna addresses the statute of limitations ground for the trial court’s ruling, she does not address the other grounds upon which the trial court sustained the demurrer on the fraud cause of action. The trial court correctly determined that the first amended complaint fails to state a cause of action for fraud because the pleading falls short of the specificity needed to state a claim for fraud and fails to allege specific facts showing all the elements of fraud. Accordingly, we need not address whether the fraud cause of action is time-barred.

“ ‘The elements of fraud, which give rise to the tort action for deceit, are (a) misrepresentation (false representation, concealment, or nondisclosure); (b) knowledge of falsity (or “scienter”); (c) intent to defraud, i.e., to induce reliance; (d) justifiable reliance; and (e) resulting damage.’ [Citations.]” (Lazar v. Superior Court (1996) 12 Cal.4th 631, 638.) To withstand demurrer, a plaintiff must plead facts constituting every element of fraud with particularity. (Kalnoki v. First American Trustee Servicing Solutions, LLC (2017) 8 Cal.App.5th 23, 35 (Kalnoki).) The plaintiff must plead facts which show how, when, where, to whom and by what means a misrepresentation was tendered. (Lazar, supra, 12 Cal.4th at p. 645.) And when the defendant is a corporation, the plaintiff must “ ‘allege the names of the persons who made the allegedly fraudulent representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written.’ ” (Ibid.) General and conclusory allegations will not suffice. (Ibid.)

Gauna alleges fraud with regard to the loan origination, the modification of the loan, the notice of default, and the assignment of the deed of trust.

A

As to the loan origination, Gauna alleges wrongful acts by LBMC. The trial court found the allegations lacked the requisite specificity, and we agree. For example, regarding the allegation that LBMC changed the interest rate for Gauna’s loan from fixed to adjustable, there is no allegation that a specified individual made a specified misrepresentation on a specified date. But there is also another deficiency. Gauna fails to allege facts showing how Chase Home Finance, Deutsche Bank and CRC can be liable for the alleged fraudulent acts by LBMC, which is not a defendant in this action.

B

Turning to the loan modification, the first amended complaint alleges the lender and Chase Home Finance represented that if Gauna entered into the TPP and complied with its terms, Chase Home Finance and the lender would modify her loan. It alleges Gauna justifiably relied on that representation and made modified payments, but Chase Home Finance and the lender refused to execute the modification agreement and instead demanded that Gauna resubmit her financial information and make another set of TPP payments. Chase Home Finance and the lender then rejected Gauna’s TPP payments, declared a default and foreclosed on the property. Gauna says she lost the property as a result of defendants’ fraud.

Gauna fails to allege a false representation because she admits she received an offer to modify her loan. The first amended complaint alleges Chase Home Finance and the lender refused to execute the loan modification agreement, but it also alleges facts showing that Gauna did not unconditionally accept the terms of the loan modification agreement. Rather, Gauna asked for an appraisal and an extension and objected that she signed the agreement with “great stress and pressure with unanswered questions.”

“ ‘[T]erms proposed in an offer must be met exactly, precisely and unequivocally for its acceptance to result in the formation of a binding contract [citations].” (Panagotacos v. Bank of America (1998) 60 Cal.App.4th 851, 855-856; see Civ. Code § 1585.) An acceptance which, as here, contains additions or limitations is a rejection of the offer and amounts to a counteroffer. (Panagotacos, at pp. 855-856; Ajax Holding Co. v. Heinsbergen (1944) 64 Cal.App.2d 665, 669-670.) A counteroffer containing a condition not in the original offer, if not accepted by the original offeror, does not result in a contract. (Ajax Holding, at pp. 669-670.) Gauna cites no authority requiring an original offeror to accept a counteroffer.

Guzman v. Visalia Community Bank (1999) 71 Cal.App.4th 1370, a case Gauna’s counsel cited during oral argument, is not on point. That decision held that general contract principles did not apply in determining whether a Code of Civil Procedure section 998 offer was rejected. (Id. at p. 1377.) But this case does not involve an offer to compromise made pursuant to Code of Civil Procedure section 998.

The first amended complaint also fails to allege facts showing knowledge of falsity, intent to defraud and that Gauna’s alleged injury — making modified payments and loss of the property — was caused by Chase Home Finance or the lender’s alleged misrepresentation. As for the last fraud element, continuing to make modified loan payments does not constitute detrimental reliance because Gauna was contractually obligated to make loan payments. (Lueras v. BAC Home Loans Servicing, LP (2013) 221 Cal.App.4th 49, 79 (Lueras); West v. JPMorgan Chase Bank, N.A. (2013) 214 Cal.App.4th 780, 795 (West).) Gauna fails to allege specific facts showing how her reliance on defendants’ promise to modify her loan caused her to default on her loan or prevented her from curing that default. (Rossberg v. Bank of America, N.A. (2013) 219 Cal.App.4th 1481, 1499-1500 (Rossberg).)

C

Regarding the notice of default, the first amended complaint alleged the notice represented that Gauna was in default by $23,358.34 as of December 22, 2010, but the representation was false because it did not account for $13,442 in TPP payments and it included improper charges. Gauna alleged Chase Home Finance and the lender caused the notice of default to be recorded even though they knew it was false. She claimed the false representation prevented her from clearing the arrears and she lost the property as a result.

A plaintiff asserting fraud must plead actual reliance, i.e., a causal relationship between the alleged misrepresentation and the harm claimed to have resulted therefrom. (OCM Principal Opportunities Fund, L.P. v. CIBC World Markets Corp. (2007) 157 Cal.App.4th 835, 864.) The plaintiff must “allege specific facts not only showing he or she actually and justifiably relied on the defendant’s misrepresentations, but also how the actions he or she took in reliance on the defendant’s misrepresentations caused the alleged damages. [Citation.]” (Rossberg, supra, 219 Cal.App.4th at p. 1499; see Lueras, supra, 221 Cal.App.4th at p. 79.) “If the defrauded plaintiff would have suffered the alleged damage even in the absence of the fraudulent inducement, causation cannot be alleged and a fraud cause of action cannot be sustained.’ ” (Rossberg, at p. 1499, italics omitted; see Lueras, at p. 79.)

The first amended complaint does not allege facts showing a causal relationship between Gauna’s alleged injury and the allegedly inflated amount stated in the notice of default. In particular, Gauna does not allege facts showing that she took or did not take some action because of the misstatement in the notice of default. (Orcilla v. Big Sur, Inc. (2016) 244 Cal.App.4th 982, 1008 (Orcilla); Hamilton v. Greenwich Investors XXVI, LLC (2011) 195 Cal.App.4th 1602, 1615 (Hamilton); Glaski v. Bank of America (2013) 218 Cal.App.4th 1079, 1091.) Her general allegation that she relied on the false representations by defendants is conclusory and insufficient to plead fraud. (Glaski, at p. 1091.) While she alleged she could have cleared the arrears, the first amended complaint indicated Gauna did not make other payments, and she stated in her appellate opening brief that she last made a payment on the note in August 2010 and she was $13,442 in arrears. She does not say she could have paid the arrears not caused by defendants’ alleged refusal to accept her payments. Without a loan modification, Gauna was still obligated to make the payments due under her note. (Lueras, supra, 221 Cal.App.4th at p. 79) The TPP Agreement expressly provided that the lender’s acceptance of a payment during the TPP period did not constitute a cure of Gauna’s default under the loan documents unless such payments were sufficient to completely cure her entire default under the loan documents. It also stated that the terms of the loan documents remained in full force and effect and the TPP did not release the obligations contained in the loan documents.

D

As for the assignment of the deed of trust, the first amended complaint alleged Colleen Irby falsely represented in the assignment that she was an officer of JPMorgan Chase, thereby obscuring the identity of the lender and preventing Gauna from resolving the servicing improprieties, which resulted in the loss of the property. But those allegations are not specific enough. They do not allege what action Gauna took or did not take in reliance on Irby’s alleged misrepresentation (Orcilla, supra, 244 Cal.App.4th at pp. 1007-1008; Hamilton, supra, 195 Cal.App.4th at p. 1615), and they do not specify exactly how she lost her property because of Irby’s alleged false representation. Gauna was in arrears and the first amended complaint does not allege that she was able to bring her loan current.

III

Gauna further argues the first amended complaint states a cause of action for breach of contract.

The elements of a cause of action for breach of contract include (1) the existence of a contract, (2) the plaintiff’s performance or excuse for nonperformance, (3) the defendant’s breach, and (4) damages to the plaintiff caused by the breach. (Orcilla, supra, 244 Cal.App.4th at p. 1005.) To the extent Gauna alleges the breach of a written contract, she may plead the contract by its terms (set out verbatim or with a copy of the contract attached to her pleading and incorporated therein by reference) or by its legal effect by alleging the substance of its relevant terms. (Heritage Pacific Financial, LLC v. Monroy (2013) 215 Cal.App.4th 972, 993.)

The first amended complaint alleged that the note, deed of trust and TPP were breached. The trial court took judicial notice of the note and deed of trust; those documents show an agreement between Gauna and LBMC. The note and deed of trust did not mention JPMorgan Chase, Chase Home Finance or Deutsche Bank. Further, based on the allegations of the first amended complaint, neither JPMorgan Chase nor Deutsche Bank is a successor in interest to LBMC. The first amended complaint did not allege facts showing the existence of a note or deed of trust between Gauna, on the one hand, and JPMorgan Chase, Chase Home Finance or Deutsche Bank, on the other, and the terms of any such note or deed of trust. Therefore, the trial court properly sustained the demurrer to the breach of contract cause of action based on the note and deed of trust because Gauna cannot assert a claim for breach of contract against an entity that is not a party to the contract. (Universal Bank v. Lawyers Title Ins. Corp. (1997) 62 Cal.App.4th 1062, 1066 (Universal Bank); Tri-Continent International Corp. v. Paris Savings & Loan Assn. (1993) 12 Cal.App.4th 1354, 1359 (Tri-Continent).)

Turning to the TPP agreement, the first amended complaint alleged Chase Home Finance and the lender breached that agreement by refusing to execute the loan modification and by failing to provide Gauna with a fair and reasonable modification agreement.

Exhibit 3 to the first amended complaint is a copy of the purported TPP agreement. That exhibit includes a three-page document entitled “Home Affordable Modification Trial Period Plan” (hereafter TPP agreement) and a cover letter from “JPMorgan Chase Bank, N.A., successor to Washington Mutual Bank.” Chase Home Finance and Deutsche Bank are not mentioned in the TPP agreement. Moreover, the first amended complaint fails to state facts showing that Chase Home Finance or Deutsche Bank are parties to the TPP agreement. Accordingly, the first amended complaint fails to state breach of contract claims against Chase Home Finance and Deutsche Bank based on the TPP agreement. (Universal Bank, supra, 62 Cal.App.4th at p. 1066; Tri-Continent, supra, 12 Cal.App.4th at p. 1359.)

The TPP agreement said if Gauna was in compliance with the TPP and her representations in the document continued to be true, JPMorgan Chase would provide her with a Home Affordable Modification Agreement which would amend the note. JPMorgan Chase does not argue that the TPP agreement is not a contract. Under the terms of the TPP agreement, JPMorgan Chase was obligated to provide Gauna with a loan modification agreement if Gauna complied with the terms of the TPP and her representations in the document continued to be true. (Bushell v. JPMorgan Chase Bank, N.A. (2013) 220 Cal.App.4th 915, 925-928 (Bushell); Wigod v. Wells Fargo Bank, N.A. (7th Cir. 2012) 673 F.3d 547, 560-561 (Wigod).)

However, the first amended complaint alleges that Gauna received a Home Affordable Modification Agreement (loan modification agreement). The facts alleged do not, therefore, demonstrate a breach of contract. Gauna did not unequivocally accept the terms of the loan modification agreement. She does not state a cause of action for breach of contract based merely on the argument that defendants were required to accept her counteroffer.

The first amended complaint also claims defendants breached the TPP agreement by failing to offer a fair and reasonable loan modification agreement. We agree with Gauna that a lender’s duty to offer a loan modification pursuant to a TPP includes a duty to offer a good faith permanent loan modification. (Bushell, supra, 220 Cal.App.4th at pp. 925-928; West, supra, 214 Cal.App.4th at pp. 796-799; Wigod, supra, 673 F.3d at p. 565.) But Gauna argues the loan modification agreement was not in good faith because it was a contract of adhesion presented to her on a “take it or leave it” basis, it inexplicably increased her principal balance by $3,200, it included a balloon payment of $38,513.47, and it had vague terms that were prejudicial to her.

The phrase contract of adhesion “signifies a standardized contract, which, imposed and drafted by the party of superior bargaining strength, relegates to the subscribing party only the opportunity to adhere to the contract or reject it.” (Neal v. State Farm Ins. Cos. (1961) 188 Cal.App.2d 690, 694.) A contract of adhesion is nevertheless enforceable according to its terms unless it defeats the reasonable expectations of the weaker or adhering party, and even if consistent with the reasonable expectations of the adhering party, it is unduly oppressive or unconscionable. (Lona v. Citibank, N.A. (2011) 202 Cal.App.4th 89, 108; Intershop Communications AG v. Superior Court (2002) 104 Cal.App.4th 191, 201; Allan v. Snow Summit, Inc. (1996) 51 Cal.App.4th 1358, 1375.) Unconscionability has both procedural and substantive elements. (Lona, supra, 202 Cal.App.4th at p. 109.) Substantive unconscionability may exist when a contract has overly-harsh or one-sided results or when it reallocates the risks of the bargain in an objectively unreasonable or unexpected manner. (A & M Produce Co. v. FMC Corp. (1982) 135 Cal.App.3d 473, 487.)

The first amended complaint did not allege facts showing how the loan modification agreement defeated Gauna’s objectively reasonable expectations. (Lee v. Interinsurance Exchange (1996) 50 Cal.App.4th 694, 721-724.) Gauna had to allege specific facts because an allegation that a contract is unconscionable is mere legal conclusion. (Shadoan v. World Sav. & Loan Assn. (1990) 219 Cal.App.3d 97, 103.)

The loan modification agreement stated that the modified principal balance on the note would include all past due amounts, including unpaid and deferred interest, fees, escrow advances and other costs (but not unpaid late charges), less any amounts paid to the lender but not previously credited to Gauna’s loan. The cover letter to the TPP similarly advised Gauna that past due amounts, including unpaid interest, taxes, insurance and assessments paid on Gauna’s behalf to a third party, would be added to the principal loan balance. According to the first amended complaint, no monthly loan payments were made on Gauna’s loan for two months in 2009 and for at least four months in 2010. On this record, an approximately $3,200 increase in the principal loan balance was not without explanation and was not substantively unconscionable.

In addition, Gauna offers no facts showing that the terms of the proposed modified loan or other circumstances were overly-harsh or one-sided and unjustified. She does not present legal analysis with citation to supporting authority establishing that the loan modification agreement is unenforceable, and we are not obligated to perform that function for her. (Okasaki v. City of Elk Grove (2012) 203 Cal.App.4th 1043, 1045, fn. 1 (Okasaki); Keyes v. Bowen (2010) 189 Cal.App.4th 647, 656 (Keyes).)

Furthermore, the first amended complaint failed to allege damages caused by defendants’ breach of the TPP agreement. It alleged Gauna was forced to continue to pay under the unconscionable terms of the note, lost her property and incurred legal fees and costs because of defendants’ breaches, but it did not allege that Gauna was not in default under her loan and that absent the alleged breaches by defendants, Gauna would have avoided foreclosure and the loss of the property. (Orcilla, supra, 244 Cal.App.4th at p. 1005.)

The first amended complaint fails to state a cause of action for breach of contract against JPMorgan Chase, Chase Home Finance and Deutsche Bank. Accordingly, we need not address whether any such cause of action is time-barred.

IV

Gauna claims the trial court erred in ruling that she lacked standing to challenge the assignment of the deed of trust, and that tender was required to state a cause of action for wrongful foreclosure.

After the trial court ruled that Gauna lacked standing to challenge the assignment of the deed of trust, the California Supreme Court held in Yvanova, supra, 62 Cal.4th 919, that a borrower of a home loan secured by a deed of trust who has been subjected to a nonjudicial foreclosure has standing to sue for wrongful foreclosure based on an allegedly void assignment of the note and deed of trust — e.g., that the foreclosing entity lacked authority to pursue foreclosure — even if the borrower is in default on the loan and is not a party to the challenged assignment. (Id. at pp. 924, 935, 939.) Under Yvanova, Gauna has standing to challenge the assignment of the deed of trust if the assignment is void but not where the assignment is voidable. (Id. at pp. 942-943.) We independently evaluate the first amended complaint to determine whether it alleges a void assignment.

A suit for wrongful foreclosure is an equitable action to set aside a foreclosure sale, or an action for damages resulting from the sale, based on the assertion that the foreclosure was improper. (Sciarratta v. U.S. Bank National Assn. (2016) 247 Cal.App.4th 552, 561.) To succeed on a wrongful foreclosure cause of action, the plaintiff must show that (1) the trustee or mortgagee caused an illegal, fraudulent or willfully oppressive sale of real property pursuant to a power of sale in a mortgage or deed of trust; (2) the party attacking the sale was prejudiced or harmed; and (3) in cases where the trustor or mortgagor challenges the sale, the trustor or mortgagor tendered the amount of the secured indebtedness or was excused from tendering. (Id. at pp. 561-562.)

In a nonjudicial foreclosure, only the holder of the beneficial interest under the mortgage or deed of trust or its agent may direct the trustee to sell the property. (Civ. Code, § 2924, subd. (a)(1), (6); Yvanova, supra, 62 Cal.4th at pp. 929, 935.) If a foreclosing entity claims the power to foreclose based on a void assignment, the foreclosing entity has acted without legal authority and such an unauthorized sale constitutes a wrongful foreclosure. (Yvanova, supra, 62 Cal.4th at pp. 929, 935.)

Here, the first amended complaint alleged (1) the lender could not exercise the power of sale because Chase Home Finance and the lender breached the note and deed of trust, (2) the nonjudicial foreclosure was wrongful because the notice of default was deficient in that it inflated the arrears amount and falsely claimed that the notice was issued by CRC as trustee (when LBMC was the trustee) and that JPMorgan Chase was the beneficiary, (3) CRC was not a validly substituted trustee, and (4) Deutsche Bank was not the beneficiary under the deed of trust and thus could not enter a credit bid.

Regarding the first allegation, we have already concluded Gauna fails to state a cause of action for breach of the note and deed of trust against JPMorgan Chase, Chase Home Finance and Deutsche Bank. As for the allegedly deficient notice of default, the notice contained the statements required under Civil Code section 2924, subdivision (a)(1) and the first amended complaint does not allege facts showing that the information in the notice caused Gauna injury. However, the first amended complaint states a cause of action for wrongful foreclosure by alleging facts showing that CRC (which Deutsche Bank substituted as the new trustee) had no authority to conduct the nonjudicial foreclosure because JPMorgan Chase, the entity from which Deutsche Bank purportedly obtained an assignment of the deed of trust, did not own a beneficial interest in the loan and deed of trust and, therefore, had no authority to assign the deed of trust to Deutsche Bank.

Defendants say the claim that the assignment is void is based on the late transfer of the note into the LBM Trust. But the first amended complaint alleged other facts which Gauna asserts rendered the assignment void. The first amended complaint alleged that the note and deed of trust were sold before WaMu became LBMC’s successor in interest. Therefore, according to the first amended complaint, JPMorgan Chase did not acquire any interest in the note and deed of trust when it purchased WaMu’s assets from the FDIC. Contrary to the assertion by counsel for JPMorgan Chase at oral argument, Gauna raised this issue in her appellate opening brief. She urges on appeal that her loan was sold before LBMC merged with WaMu and, therefore, JPMorgan Chase did not acquire her loan from the FDIC. She complains that the trial court failed to address that allegation.

The case of Sciarratta, supra, 247 Cal.App.4th 552, is instructive. In that case, the plaintiff executed a promissory note secured by a deed of trust identifying WaMu as the lender. (Sciarratta, supra, 247 Cal.App.4th at pp. 556-557.) About four years later, JPMorgan Chase, as successor in interest to WaMu, assigned the note and deed of trust to Deutsche Bank, as trustee for Long Beach Mortgage Loan Trust 2006-6. (Id. at p. 557.) The plaintiff defaulted on her loan and the trustee recorded a notice of default and trustee’s sale. (Ibid.) JPMorgan Chase then assigned the note and deed of trust to Bank of America, which foreclosed on the deed of trust. (Id. at pp. 557-558.) The plaintiff brought a wrongful foreclosure action, alleging that the assignment to Bank of America was void and Bank of America had no right to foreclose because JPMorgan Chase had previously assigned the note and deed of trust to Deutsche Bank. (Id. at pp. 561-562.) The documents subject to judicial notice were consistent with the plaintiff’s allegations. (Id. at p. 563.) The court in Sciarratta held that the assignment to the foreclosing entity (Bank of America) was void and not merely voidable because having assigned all beneficial interest in the plaintiff’s note and deed of trust to Deutsche Bank, JPMorgan Chase could not later assign the same interests to Bank of America. (Id. at p. 564.)

In this case, under the facts alleged in the first amended complaint, JPMorgan Chase could not assign the beneficial interest in the note and deed of trust to Deutsche Bank because it did not have any interest in the note and deed of trust to assign. (Sciarratta, supra, 247 Cal.App.4th at p. 564; Barrionuevo v. Chase Bank, N.A. (N.D. Cal. 2012) 885 F.Supp.2d 964, 971-974 (Barrionuevo) [the plaintiffs stated a cause of action for wrongful foreclosure where they alleged that the lender sold the beneficial interest in their deed of trust before the entity purporting to be the beneficiary under the deed of trust acquired the lender’s assets]; Burke v. JPMorgan Chase Bank, N.A (N.D. Cal. May 11, 2015, No. 13-4249SC) 2015 U.S. Dist. Lexis 61512, p. *8; Subramani v. Wells Fargo Bank N.A. (N.D. Cal. Oct. 31, 2013, No. 13-1605SC) 2013 U.S. Dist. Lexis 156556, pp. *10-11; Javaheri v. JPMorgan Chase Bank, N.A. (C.D. Cal. June 2, 2011, No. CV10-08185 ODW FFMx) 2011 U.S. Dist. Lexis 62152, pp. *13-14.)

The judicially noticeable facts do not contradict the allegations in the first amended complaint. While the assignment of the deed of trust recites that JPMorgan Chase was the successor in interest to WaMu and WaMu was the successor in interest to LBMC, we may not take judicial notice of those asserted facts because they are subject to dispute. (Herrera v. Deutsche Bank National Trust Co. (2011) 196 Cal.App.4th 1366, 1375; Glaski, supra, 218 Cal.App.4th at p. 1102.) The matters which we must accept as true for purposes of a demurrer show that the assignment from JPMorgan Chase to Deutsche Bank was void; thus, Deutsche Bank had no authority to substitute CRC as the trustee and CRC had no authority to conduct the nonjudicial foreclosure.

The first amended complaint adequately alleges that Gauna suffered harm as a result of the wrongful foreclosure in that it alleges that she lost the property as a result of the void assignment and sale of the property by one without power of sale. (Sciarratta, supra, 247 Cal.App.4th at pp. 565-567.) A void contract is a nullity and cannot be validated by any party. (Yvanova, supra, 62 Cal.4th at p. 929.) It is hard to imagine that a borrower who has lost his or her property in a sale by an entity that had no right to enforce the debt has not been prejudiced thereby. (Sciarratta, supra, 247 Cal.App.4th at pp. 565-567; see Yvanova, supra, 62 Cal.4th at pp. 937-939.)

Kalnoki, supra, 8 Cal.App.5th 23 is inapposite. In contrast with the facts pleaded here, the judicially noticeable facts in Kalnoki showed that the entities which executed the substitution of trustee and assignment of the deed of trust and initiated the nonjudicial foreclosure were authorized to do so. (Id. at pp. 36-44.)

As respondents concede, tender is not required when the instrument or transaction sought to be cancelled or set aside is void. (Smith v. Williams (1961) 55 Cal.2d 617, 621; Sciarratta, supra, 247 Cal.App.4th at p. 565, fn. 10; Saterbak v. JPMorgan Chase Bank, N.A. (2016) 245 Cal.App.4th 808, 818-819 (Saterbak); Chavez v. Indymac Mortgage Services (2013) 219 Cal.App.4th 1052, 1063 [the plaintiff need not allege tender where the foreclosure sale was void because the defendants lacked a contractual basis to exercise the power of sale]; Glaski, supra, 218 Cal.App.4th at p. 1100; Cheung v. Wells Fargo Bank, N.A. (N.D. Cal. 2013) 987 F.Supp.2d 972, 978; Barrionuevo, supra, 885 F.Supp.2d at pp. 969-971.)

Based on the above, the trial court erred in sustaining the demurrer to the wrongful foreclosure cause of action.

V

Gauna also contends the trial court erred in sustaining the demurrer to her causes of action for cancellation of instruments, slander of title and violation of Business and Professions Code section 17200 et seq. We will address each cause of action in turn.

A

We begin with the cause of action for cancellation of instruments. Civil Code section 3412 provides: “A written instrument, in respect to which there is a reasonable apprehension that if left outstanding it may cause serious injury to a person against whom it is void or voidable, may, upon his application, be so adjudged, and ordered to be delivered up or canceled.” To obtain cancellation, a plaintiff must allege facts showing that the instrument is void or voidable and would cause serious injury if not canceled. (Deutsche Bank National Trust Co. v. Pyle (2017) 13 Cal.App.5th 513, 523; Saterbak, supra, 245 Cal.App.4th at pp. 818-819; Kroeker v. Hurlbert (1940) 38 Cal.App.2d 261, 266.) Here, the cause of action for cancellation of instruments seeks to cancel the note and deed of trust, the assignment of the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale.

The first amended complaint alleges LBMC was not the actual lender on Gauna’s loan and provided no consideration for the note because the loan was table-funded by Doe investors. “ ‘Table-funding’ is defined as a ‘settlement at which a loan is funded by a contemporaneous advance of loan funds and an assignment of the loan to the person advancing the funds.’ [Citation.] In a table-funded loan, the originator closes the loan in its own name, but is acting as an intermediary for the true lender, which assumes the financial risk of the transaction.” (Easter v. Am. West Fin. (9th Cir. 2004) 381 F.3d 948, 955, fn. omitted.) The first amended complaint alleges the note and deed of trust are void because they did not identify the real lender and there was no consideration from LBMC. Gauna argues that because of the table-funding and securitization of her loan, the parties who provided the consideration were concealed in violation of Civil Code sections 1550 and 1558, and there was no mutual consent as required under Civil Code section 1580.

Civil Code section 1558 says the ability to identify the parties to a contract is essential to a contract’s validity. In this case, the promissory note identifies the lender and the borrower. While Gauna alleges Doe investors actually provided the funds that LBMC lent Gauna, she cites no authority that such an arrangement invalidates the contractual relationship between Gauna and LBMC under the note. (Logvinov v. Wells Fargo Bank (N.D. Cal. Dec. 9, 2011, No. C-11-04772 DMR) 2011 U.S. Dist. Lexis 141988, pp. *8-9 [securitization does not change the relationship of the parties to the note]; Sepehry-Fard v. Nationstar Mortg. LLC (N.D. Cal. Jan. 26, 2015, No. 14-CV-03218-LHK) 2015 U.S. Dist. Lexis 8790, p. *62 [securitization does not render the plaintiff’s mortgage loans unenforceable].) In any event, the first amended complaint alleges that the true parties to the note are Gauna and the investors who owned the LBM Trust. On this record it appears it was possible to identify the alleged true lender.

Civil Code section 1550 sets forth the essential elements of a contract including consideration and consent. Civil Code section 1580 provides that consent is not mutual unless the parties all agree upon the same thing in the same sense. A reasonable inference from the facts alleged in the first amended complaint is that Gauna received $168,800 in consideration for her execution of the note and deed of trust. Courts have rejected claims that table-funding voids or invalidates a loan. (Arzamendi v. Wells Fargo Bank, N.A. (E.D. Cal. Mar. 8, 2018, No. 1:17-cv-01485-CJO-SKO) 2018 U.S. Dist. Lexis 38382, p. *11; Marquez v. Select Portfolio Servicing, Inc. (N.D. Cal. Mar. 16, 2017, No. 16-cv-03012-EMC) 2017 U.S. Dist. Lexis 38239, p. *7; Grieves v. MTC Financial Inc. (N.D. Cal. July 25, 2017, No. 17-CV-01981-LHK) 2017 U.S. Dist. Lexis 116458, p. *37, fn. 1; see Silas v. Argent Mortgage Co., LLC (E.D. Cal. July 24, 2017, No. 1:17-cv-00703-LJO-JLT) 2017 U.S. Dist. Lexis 115324, p. *27; Sotanski v. HSBC Bank USA, National Assn. (N.D. Cal. Aug. 12, 2015, No. 15-cv-01489-LHK) 2015 U.S. Dist. Lexis 106859, pp. *17-18; Ghalehtak v. FNBN I, LLC (N.D. Cal. May 6, 2016, No. 15-cv-05821-LB) 2016 U.S. Dist. Lexis 61347, p. *9; Major v. Imortgage.com, Inc. (C.D. Cal. Feb. 8, 2016, No. 5:15-cv-02592-CASDTBx) 2016 U.S. Dist. Lexis 15225, pp. *9-10.)

Courts have also rejected the argument that a lender loses its interest in a note when it is securitized. (Sepehry-Fard v. Nationstar Mortg. LLC, supra, 2015 U.S. Dist. Lexis 8790, p. *62; Ramirez v. J.P. Morgan Chase Bank, N.A. (E.D. Cal. June 7, 2013, No. 1:13-CV-352 AWI GSA) 2013 U.S. Dist. Lexis 80624, p. *10 [securitization of the note does not affect the ability to foreclose]; Hague v. Wells Fargo Bank, N.A. (N.D. Cal. Dec. 6, 2011, No. C11-02866 TEH) 2011 U.S. Dist. Lexis 140122, p. *16; Logvinov v. Wells Fargo Bank, supra, 2011 U.S. Dist. Lexis 141988, pp. *8-9; Wadhwa v. Aurora Loan Services, LLC (E.D. Cal. July 8, 2011, No. S-11-1784 KJM KJN) 2011 U.S. Dist. Lexis 73949, pp. *9-10; Lane v. Vitek Real Estate Indus. Group (E.D. Cal 2010) 713 F.Supp.2d 1092, 1099; Hafiz v. Greenpoint Mortgage Funding, Inc. (N.D. Cal. 2009) 652 F.Supp.2d 1039, 1043.) Gauna cites no authority voiding a note or deed of trust based on table-funding or securitization.

Gauna claims on appeal that her loan was paid off. But courts have rejected claims that a borrower is relieved of his or her mortgage obligation when the lender received payment in full upon the securitization of a note. (Javaheri v. JPMorgan Chase Bank, N.A., supra, 2011 U.S. Dist. Lexis 62152, pp. *13-14; Hague v. Wells Fargo Bank, N.A., supra, 2011 U.S. Dist. Lexis 140122, p. *16; West v. Bank of America, N.A. (D. Nev. June 22, 2011, No. 2:10-CV-1966 JCM GWF) 2011 U.S. Dist. Lexis 66726, p. *5.)

Gauna also argues that the securitization of her loan introduced new parties, terms and risks to her loan contract. However, the first amended complaint does not allege, and Gauna’s appellate brief does not state, facts showing such alteration. Gauna’s conclusory statements are insufficient to plead a void or voidable contract. (New v. Mutual Benefit Health & Accident Assn. (1938) 24 Cal.App.2d 681, 683 [allegation that policy is “in contravention of the laws of the State of California” and is void are mere conclusions of law]; see 5 Witkin, Cal. Procedure (5th ed. 2008) Pleading, § 674, p. 98 [to state an action to remove cloud over title, facts showing actual invalidity of apparently valid instrument must be specifically pleaded].) The first amended complaint failed to allege facts showing that the note and deed of trust are void or voidable.

The cause of action for cancellation of instruments also seeks to cancel the assignment of the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale.

The first amended complaint alleges the assignment of the deed of trust is void because (1) JPMorgan Chase had no valid interest in the note or deed of trust, (2) the interest in Gauna’s note and deed of trust was assigned to Deutsche Bank after the closing date of the LBM Trust, and (3) Colleen Irby was not an officer of JPMorgan Chase and had no authority to execute the assignment for JPMorgan Chase. The first amended complaint alleges that the notice of default, notice of trustee’s sale and trustee’s deed upon sale must be cancelled in part because CRC was not the duly authorized trustee and Deutsche was not the beneficiary under the deed of trust. Those allegations appear to be based on the alleged void assignment by JPMorgan Chase.

As we have explained, the assignment of the deed of trust is void under the facts alleged because JPMorgan Chase had no interest in the note or deed of trust to assign. The first amended complaint alleges sufficient facts showing that Gauna would suffer a serious injury if the void assignment is not canceled. (Cf. Saterbak, supra, 245 Cal.App.4th at pp. 819-820 [no “ ‘serious injury’ ” where assignment was voidable because defective assignment did not change the borrower’s payment obligations under the note].) Tender is not required to state a cause of action for cancellation of instruments because Gauna adequately alleged that the assignment is void and not merely voidable. (Sciarratta, supra, 247 Cal.App.4th p. 568.)

In addition, because the assignment to Deutsche Bank is void under the facts alleged, Deutsche Bank had no authority to substitute CRC as the trustee under the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale, and those documents are also void under the facts alleged.

The judgment as to the cancellation of instruments cause of action must be reversed with regard to the assignment of the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale.

B

With regard to her cause of action for slander of title, Gauna contends the trial court erred in concluding that (a) the deed of trust, substitution of trustee, and trustee’s deed upon sale were privileged under Civil Code section 2924, subdivision (d)(1), (b) the privilege applied because CRC was the trustee under the deed of trust, (c) Gauna must allege malice, and (d) loss of title and investment in the property was not a direct pecuniary loss.

“Slander or disparagement of title occurs when a person, without a privilege to do so, publishes a false statement that disparages title to property and causes the owner thereof ‘ “some special pecuniary loss or damage.” ’ [Citation.] The elements of the tort are (1) a publication, (2) without privilege or justification, (3) falsity, and (4) direct pecuniary loss. [Citations.] If the publication is reasonably understood to cast doubt upon the existence or extent of another’s interest in land, it is disparaging to the latter’s title. [Citation.] The main thrust of the cause of action is protection from injury to the salability of property [citations], which is ordinarily indicated by the loss of a particular sale, impaired marketability or depreciation in value [citations].” (Sumner Hill Homeowners’ Assn., Inc. v. Rio Mesa Holdings, LLC (2012) 205 Cal.App.4th 999, 1030.) The pecuniary loss element is also satisfied by attorney’s fees and costs necessary to clear title. (Id. at pp. 1030-1031.)

The slander of title cause of action in the first amended complaint is based on the recording of the assignment of the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale. Gauna fails to show how the recording of the assignment of the deed of trust and the substitution of trustee disparaged her title to the property. The first amended complaint does not state a slander of title cause of action based on the recording of those documents.

However, the recording of the notice of default, the notice of trustee’s sale, and the trustee’s deed upon sale constitute publications for purposes of a slander of title cause of action. (Ghuman v. Wells Fargo Bank, N.A. (E.D. Cal. 2013) 989 F.Supp.2d 994, 1000 (Ghuman).) The first amended complaint alleged those documents contained false statements of material fact and their recording impaired Gauna’s title to the property. The alleged falsity was that CRC was authorized to conduct a nonjudicial foreclosure under the deed of trust.

Nevertheless, the recording of a notice of default, a notice of sale, and a trustee’s deed upon sale is protected by a qualified privilege. (Civ. Code, § 2924, subd. (d)(1), (2); Schep v. Capital One, N.A. (2017) 12 Cal.App.5th 1331, 1336; Kachlon v. Markowitz (2008) 168 Cal.App.4th 316, 333.) The privilege protects communications made without malice. (Kachlon, at p. 336.) Malice means the defendant was “ ‘ “motivated by hatred or ill will towards the plaintiff” ’ ” or “ ‘ “lacked reasonable grounds for belief in the truth of the publication and therefore acted in reckless disregard of the plaintiff’s rights.” ’ ” (Ibid.) Implied malice is sufficient to defeat the qualified privilege. (Contra Costa County Title Co. v. Waloff (1960) 184 Cal.App.2d 59, 66.)

The first amended complaint alleged JPMorgan Chase, Chase Home Finance, CRC and Deutsche Bank knew the recorded documents contained false representations and intended the recorded documents “to have a specific legal effect based on those false representations.” We understand the allegation to mean that JPMorgan Chase, Chase Home Finance, CRC and Deutsche Bank intended to use the recorded documents to foreclose on the property even though they knew they did not have a right to foreclose because JPMorgan Chase never acquired an interest in the note and deed of trust. The first amended complaint alleges sufficient facts to plead malice. (Ghuman, supra, 989 F.Supp.2d at p. 1000 [allegation that the defendants’ recording of documents was “ ‘knowingly wrongful’ ” was sufficient to defeat the privilege]; Barrionuevo, supra, 885 F.Supp.2d at p. 975 [allegations that the defendants published a notice of trustee’s sale with “ ‘malice and a reckless disregard for the truth’ ” and the publications were false were sufficient to withstand challenge to the pleading]; Davis v. Wood (1943) 61 Cal.App.2d 788, 794-795 [allegation that the defendants recorded documents maliciously and with knowledge that their claims were wholly false was sufficient to negative any privilege].)

Gauna alleged the recording of the challenged documents diminished the marketability of her title to the property and caused her to lose her investment in the property through an improper foreclosure. That is sufficient to allege the “ ‘direct pecuniary loss’ ” element of a slander of title cause of action. (Barrionuevo, supra, 885 F.Supp.2d at p. 975.)

Based on the above, the trial court erred in sustaining the demurrer to the slander of title cause of action as to the recording of the notice of default, the notice of trustee’s sale, and the trustee’s deed upon sale. But Gauna fails to demonstrate error as to the recording of the assignment of the deed of trust and the substitution of trustee.

C

Turning to the cause of action for violation of Business and Professions Code section 17200 et seq., the trial court concluded Gauna failed to show standing because her factual allegations did not demonstrate an economic injury caused by the defendants’ conduct. We agree.

Gauna’s Business and Professions Code cause of action is based on the following alleged acts: Chase Home Finance and the lender refused to accept Gauna’s loan payments, refused to execute the loan modification agreement, and caused to be recorded a notice of default that did not account for all monies paid and inflated the arrears; CRC falsely claimed to be the trustee; and Deutsche Bank accepted late assignments into the LBM Trust.

Business and Professions Code section 17200 et seq. prohibits and provides civil remedies for any unlawful, unfair or fraudulent business act or practice. Actions for relief by a private plaintiff are limited to those who have been injured in fact and lost money or property as a result of an unlawful, unfair or fraudulent business act or practice. (Bus. & Prof. Code, § 17204.) The plaintiff must plead general facts showing an economic injury which was caused by the defendant’s unlawful, unfair or fraudulent business act or practice. (Kwikset Corp. v. Superior Court (2011) 51 Cal.4th 310, 322, 327.)

When a Business and Professions Code section 17200 et seq. claim is derivative of other substantive causes of action, the claim “stand[s] or fall[s] depending on the fate of the antecedent substantive causes of action.” (Krantz v. BT Visual Images (2001) 89 Cal.App.4th 164, 178.) Regarding the alleged refusal to accept Gauna’s loan payments, the first amended complaint fails to state a breach of contract cause of action against JPMorgan Chase, Chase Home Finance and Deutsche Bank and Gauna fails to demonstrate how the refusal to accept loan payments constitutes an unlawful, unfair or fraudulent business act or practice by any defendant. As for the allegation that Chase Home Finance and the lender refused to execute the loan modification agreement, as we have explained, Gauna rejected the offer of a modification and she cites no authority mandating acceptance of her counteroffer. Because her claims are not supported by legal analysis and citation to authority, they are forfeited. (Okasaki, supra, 203 Cal.App.4th at p. 1045, fn. 1; Keyes, supra, 189 Cal.App.4th at p. 656.) The first amended complaint does not state facts showing an unlawful, unfair or fraudulent business act or practice based on those allegations.

With regard to the other bases for the Business and Professions Code section 17200 et seq. cause of action, the first amended complaint does not allege facts showing a causal connection between the alleged wrongful act and the alleged injury. A plaintiff fails to plead a causal connection between the alleged injury and the unlawful, unfair or fraudulent business act or practice if he or she would have suffered the same harm regardless of the defendant’s act or practice. (Jenkins v. JPMorgan Chase Bank, N.A. (2013) 216 Cal.App.4th 497, 522 (Jenkins), disapproved on another ground in Yvanova, supra, 62 Cal.4th at p. 939, fn. 13; Daro v. Superior Court (2007) 151 Cal.App.4th 1079, 1099 (Daro).)

Gauna represented that she was unable to pay her regular monthly loan payments. She began making modified loan payments in May 2009. The first amended complaint alleges the notice of default overstated the amount of arrears by over $13,422, but it does not allege Gauna would not otherwise have defaulted on the note. The order sustaining the demurrer was proper because the first amended complaint failed to allege that Gauna would not have been injured absent defendants’ wrongful acts. (Graham v. Bank of America, N.A. (2014) 226 Cal.App.4th 594, 614; Jenkins, supra, 216 Cal.App.4th at p. 523; Daro, supra, 151 Cal.App.4th at p. 1099; Diunugala v. JP Morgan Chase Bank, N.A. (S.D. Cal. 2015) 81 F.Supp.3d 969, 992.)

Gauna identifies additional alleged acts or omissions in her appellant’s opening brief that she claims constituted violations of Business and Professions Code section 17200 et seq., but her assertion is forfeited because she fails to provide legal argument and citation to authority in support. (Okasaki, supra, 203 Cal.App.4th at p. 1045, fn. 1; Keyes, supra, 189 Cal.App.4th at p. 656.) “ ‘The absence of cogent legal argument or citation to authority allows this court to treat the contention as waived.’ ” (Cahill v. San Diego Gas & Electric Co. (2011) 194 Cal.App.4th 939, 956.)

VI

Gauna claims the trial court erred in denying her leave to amend. We consider whether the challenged pleading might state a cause of action if the appellant were permitted to amend. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) If the complaint could be amended to state a cause of action, the trial court abused its discretion in denying leave to amend and we will reverse; if not, there has been no abuse of discretion and we will affirm. (Ibid.) The appellant bears the burden of showing a reasonable possibility that a defect can be cured by amendment. (Ibid.)

The allegations in the first amended complaint are substantially the same as those in the original complaint. Gauna fails to demonstrate that she can amend her first amended complaint to state a cause of action for fraud and deceit, breach of contract and violation of Business and Professions Code section 17200 et seq.

Gauna’s appellant’s opening brief “seeks the right to add claims for Promissory Estoppel, Intentional Misrepresentations, Negligence, and Tortious Interference.” We need not consider her request because it is not supported by legal analysis and citation to authority. (Okasaki, supra, 203 Cal.App.4th at p. 1045, fn. 1; Keyes, supra, 189 Cal.App.4th at p. 656.)

VII

Gauna further contends the trial court erred in hearing defendants’ demurrer before her discovery motions. She filed motions to compel further discovery responses and for monetary sanctions against defendants after the trial court sustained the demurrer to the original complaint. The discovery motions were set to be heard after the deadline for Gauna to file a first amended complaint. But the parties stipulated to continue the hearing on the discovery motions as they attempted to resolve the issues raised in the motions. Thereafter, the trial court dismissed the action when Gauna failed to file an amended complaint, and it took all hearing dates off its calendar. The trial court subsequently vacated the judgment of dismissal.

In the meantime, defendants notified the trial court they would demur to the first amended complaint and asked that Gauna’s discovery motions not be re-calendared until after the trial court heard the demurrer. Gauna asked that her discovery motions be re-calendared. The trial court directed the court clerk to file Gauna’s first amended complaint and set a hearing on her discovery motions for September 26, 2014. But defendants filed their demurrer to the first amended complaint and the hearing on the demurrer was set before the hearing on the discovery motions. After sustaining the demurrer to the first amended complaint without leave to amend, the trial court dropped the hearing on the discovery motions as moot.

We review the trial court’s scheduling decisions for abuse of discretion. (In re Marriage of Seagondollar (2006) 139 Cal.App.4th 1116, 1130; see Dailey v. Sears, Roebuck & Co. (2013) 214 Cal.App.4th 974, 1004.) Here, the record does not show that the trial court abused its discretion in setting the order in which it would hear the parties’ motions. There is no reporter’s transcript or other document indicating the trial court’s reasons for scheduling the hearing dates. Gauna fails to demonstrate error. (Rhule v. WaveFront Technology, Inc. (2017) 8 Cal.App.5th 1223, 1228-1229; Stasz v. Eisenberg (2010) 190 Cal.App.4th 1032, 1039.)

DISPOSITION

The judgment is reversed regarding the wrongful foreclosure cause of action. It is also reversed regarding the cancellation of instruments cause of action as it pertains to the assignment of the deed of trust, the notice of default, the substitution of trustee, the notice of trustee’s sale, and the trustee’s deed upon sale. In addition, the judgment is reversed regarding the slander of title cause of action as it pertains to the recording of the notice of default, the notice of trustee’s sale, and the trustee’s deed upon sale. The judgment is otherwise affirmed. Gauna shall recover her costs on appeal. (Cal. Rules of Court, rule 8.278(a)(3).)

/S/

MAURO, J.

We concur:

/S/

BLEASE, Acting P. J.

/S/

DUARTE, J.

Why didn’t California’s vaccine mandate stop the measles? By Ethan Huff

Patient-Sick-Measles-Chick-Pocks-Red-Marks-Spots
Why didn’t California’s vaccine mandate stop the measles?
05/02/2019 / By Ethan Huff

https://www.newstarget.com/2019-05-02-why-didnt-californias-vaccine-mandate-stop-the-measles.html

On June 30, 2015, then-California Governor Jerry Brown signed into law the infamous Senate Bill 277, an authoritarian legislative bill proudly sponsored and aggressively pushed by Senator Richard Pan of Sacramento that eliminated all vaccine exemptions throughout the Golden State, save for those considered to be medical in nature – meaning only licensed doctors are allowed to sign off on them.

Co-sponsored by Sen. Ben Allen of Redondo Beach, SB 277 was supposed to eliminate all measles outbreaks, or so we were told, like the one that occurred at Disneyland back in 2014, which Pan blamed on children who hadn’t been vaccinated with Merck & Co.’s MMR vaccine for measles, mumps, and rubella.

But if Pan’s claims about unvaccinated children causing measles outbreaks like this are actually true, then why is California right now experiencing what the mainstream media is describing as a “serious” measles outbreak, more than four years after SB 277 became law, that’s reportedly already led to at least two public college campuses having to quarantine their students and faculty?

According to official news reports, more than 200 students and faculty members just in the Southern California area have been confirmed to have measles, and all of them were recently ordered to stay home and avoid all contact with others – but how is this scenario even possible with Pan’s disease-preventing vaccine legislation in place?

The only reasonable and logical answer, of course, is that, even when vaccines are mandated basically at gunpoint, they don’t actually stop disease outbreaks. And in the case of measles, anyway, the MMR vaccine, which has repeatedly been shown to cause autism, doesn’t even work as claimed at preventing measles.

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For related news, be sure to check out Vaccines.news.

Merck is right now being sued for publishing fake efficacy data about its MMR vaccine
We now know that Merck has been falsifying vaccine safety and efficacy data for a very long time, publishing fake research data about the MMR vaccine, in particular suggesting that it provides some protection against measles, mumps and rubella, without causing harmful side effects.

In truth, however, the MMR vaccine doesn’t actually work, and isn’t at all safe, despite what fake news outlets, including Fox News, are now claiming in an attempt to scare the public into rushing out and getting jabbed with MMR.

Children’s Health Defense, a health freedom child advocacy group, is actually in the process of suing Merck over its falsified MMR data, which continues to harm and kill innocent children whose parents have been falsely led to believe that the MMR vaccine is both safe and effective – when it’s actually neither.

“If you’re wondering why so many people who were vaccinated against measles, mumps and rubella are now being infected with the measles, you have to remember that Merck faked its MMR vaccine efficacy data by spiking human blood samples with animal antibodies, according to two former Merck employees who say they were ordered by Merck management to carry out the massive science fraud,” warns Mike Adams, the Health Ranger.

So-called “herd immunity” is a total fraud
Another massive science fraud being foisted on the masses is the concept of “herd immunity,” which maintains that vaccines only work if everybody gets them. Not only is such an idea completely preposterous from a medical standpoint, but it’s patently false in every way. Vaccines don’t even provide real immunity, it turns out, but rather temporary, or artificial, “immunity,” at best, that wanes over time, leaving patients susceptible to not only contracting future infections, but also spreading them.

This is exactly what we saw happen during the Disneyland measles outbreak, as only 14 percent of those affected were unvaccinated, according to a JAMA Pediatrics study. The other 86 percent of those who contracted measles at Disneyland had previously been vaccinated with MMR.

It’s important to also keep in mind that those who contract diseases like measles naturally obtain permanent, lifelong immunity once the disease subsides, which is what occurred for the 14 percent of unvaccinated people at Disneyland who contracted measles. The other 86 percent, on the other hand, not only weren’t protected against measles, but are now vaccine-damaged to the point where they’ll never have permanent immunity to measles, and will likely contract it again and again.

Fake news media constantly creates mass hysteria over disease “outbreaks” in order to push more vaccines that don’t work
But because millions of Americans still believe everything they’re told by corrupt politicians and the lying fake news media outlets and industries that control them, many folks are being successfully fear-mongered into getting themselves and their children vaccinated as a way to “protect” society against measles outbreaks – which isn’t even all that big of a deal, by the way, as it’s basically like contracting chickenpox.

Millions of Americans also remain woefully unaware of the fact that many vaccines, including MMR, are loaded with harmful adjuvants like aborted human fetal tissue and deadly chemicals – and that’s because many of them simply won’t read the manufacturer-issued ingredients lists that come with vaccines, and that are republished by the CDC, for themselves.

It’s a truly sad state of affairs where everyday folks who are fully capable of doing a little homework are refusing to do so, instead choosing to believe their favorite politicians and fake news media outlets that continue to claim that legitimate safety and efficacy concerns about vaccines are just “Jenny McCarthy-inspired conspiracy theories.”

To learn more about how the fake news media and “health authorities” are deceiving the public about vaccines, be sure to check out Propaganda.news.

Sources for this article include:

NaturalNews.com

NaturalNews.com

CNN.com

NaturalNews.com

NaturalNews.com

FoxNews.com

ChildrensHealthDefense.org

NaturalNews.com

Have We Ever Been Told the Truth About ANYTHING?


It literally has gotten to where, I don’t believe anything, said at any time, by anyone, other than a handful of people. People that also have been lied to during their whole lives.


It is amazing, everything we thought we knew is wrong. The inventions of geniuses has been kept secret; people murdered and their patents stolen just to keep us in the dark. Screw the state of the planet, we want to continue making money on oil, and all energy.

What a crock of shit! And what do we do? Like a bunch of gullible cattle just accept everything, when deep down inside, most of us know it has all been a lie.

(Carbon Tax. Carbon Tax. Carbon Tax)


Carbon tax? Get fucking real! The taxes we pay go to the Federal Reserve. There is nothing Federal about the Federal Reserve, it is just one more great big fucking lie, to make us continue being the good little slaves that we are. I don’t know about you, but between the fucking crooked courts, with their crooked fucking judges finding in favor of the fucking crooks, I have had enough!

ELKINS v. UNITED STATES, 364 U.S. 206 (1960) 364 U.S. 206?? No. 126.
Argued March 28-29, 1960.   Decided June 27, 1960.
In a government of laws,” said Mr. Justice Brandeis, “existence of the government will be imperiled if it fails to observe the law scrupulously. Our Government is the potent, the omnipresent teacher. For good or for ill, it teaches the whole people by its example. Crime is contagious. If the Government becomes a lawbreaker, it breeds contempt for law; it invites every man to become a law unto himself; it invites anarchy.” 277 U.S., at 485 . (Dissenting opinion.).

It is really hard to pinpoint just when the onslaught of lies began, and even escalated. Apparently thousands of years ago. You know, scientists cannot even agree upon the age of the earth. The scientists are some of the biggest liars too.
UFOs don’t exist, there are no aliens, we landed on the moon, global warming (they’re going to have a hard time explaining global warming when it’s the ice age coming, not global warming. Then on top of that, they have everyone going around believing that it is our fault. OUR FAULT???
See: “Climate Scientist Admits To Lying, Leaking Documents” “he confessed that he had lied to obtain internal documents from the Heartland Institute, a group that questions to what extent climate change is caused by humans” .
How can it be our fault, when they were the ones keeping us using fossil fuels. They have known for at least, yes, at least, fifty years, that we could have been using clean FREE Energy! But, can you imagine what it would be like for everyone on earth to have clean, free energy? My God! Everyone would be much more equal to one another, wouldn’t they?



“Inventor of ‘Free Energy’ Electrical Generator: ‘I’ve Been Poisoned Several Times’”. Look what they did to Tesla, and any other genius that wanted to share what they had learned, with us? They have been discredited, killed, and some very recently killed.
Why has Elon Musk repeatedly been plagued with fires at his Tesla shop?

Like Obama going to Africa and telling them that they can’t have A/C and no every household needs a car. Who the fuck is he? Going to Africa, while he was the US President telling the Africans that crock of shit, while knowing that free energy was capable, and in fact, clean and free.

But you know, if we had free, clean energy, we would all be using it, and the lies about needing oil, together with the utility companies forcing bills to keep warm, bills to keep cool, bills to use the computer, we pay for everything we do. Why? Because the lies and secrecy have kept us in the dark ages.
Listen to Dr. Steven Greer sometimes. He is brilliant, and he has been trying to force disclosure for 25-30 years.


Do you know what the excuse for not doing full disclosure now is? It is because people will get so mad, that there will be meltdown. All of these people that have been foreclosed upon, all of these people that pay extremely high power bills, gas bills, all of these people that are being taxed out the ass, all these nuclear power plants that we are paying for, and will never benefit from, unless you find cancer at younger ages beneficial…


What is wrong with the people? How can we go to work every day, knowing we are living a lie, while our children and grandchildren are at school where their young developing minds are being twisted with sick gender bullshit by people running a sick experiment on all of us? And half of the US is so worried that Hillary didn’t get elected and Trump did. SO FUCKING WHAT!!! The Clintons are bigger crooks than most everyone in the US combined!
The same idiots, are so sick, they have had to be given a diagnosis of Trump Derangement Syndrome. So you get the sickos with Trump Derangement Syndrome, together with the Antifa, and the fascists and the communists in this country, and before long, I hate it, but before long, unless the sleeping half awakens soon, we will be just like Venezuela, where they are so hungry, they have eaten all of the animals out of the zoos, they have eaten their pets, and the pets of their neighbors. Last I heard, they were eating all of the grass growing on the ground. And these people want socialism???? Where the fuck did we get these people from.
You know what I saw a day or two ago? I saw where in the Court’s instructions, and the Court’s rules, you are no longer allowed to refer to the gender of a person. People are no longer male, or female, they are whatever the hell they claim they are that day. A dog, a mule, a building, an airplane…
What the fuck people!?! Get over the bullshit!

I could go on all day with the things we have been lied to about. Take my word for it. Everything we’ve ever been told, history, current, whenever, it has all been a lie…

Poop Patrol: San Fran deploys squads to clear streets of human feces after residents raise stink


FILE PHOTO © Spencer Platt / AFP

Poop Patrol: San Fran deploys squads to clear streets of human feces after residents raise stink
Published time: 15 Aug, 2018 12:06
Edited time: 16 Aug, 2018 09:33
https://www.rt.com/usa/436012-san-francisco-poop-patrols/
Poop Patrol: San Fran deploys squads to clear streets of human feces after residents raise stink

San Francisco has established ‘Poop Patrols’ to deal with human waste that’s contaminating sidewalks in one of America’s wealthiest cities, sometimes making them almost impassable.


Read more: https://www.rt.com/usa/431838-san-francisco-human-feces/

A homeless person in San Francisco Complaints soar as San Francisco drowns in human waste

The city is about to launch the ‘Poop Patrols’ squad to remove man-made feces from the streets, the San Francisco Chronicle reported. The task force, made up of five Public Works staffers, will begin patrolling sidewalks “in about a month.”

‘Poop Patrol’ will begin its unenviable work in the afternoon, by which time piles of feces tend to become visible. The poo crew will travel in a vehicle equipped with a steam cleaner. “We’re trying to be proactive,” explained Public Works Director Mohammed Nuru. “We’re actually out there looking for it.”

The Chronicle, however, good-naturedly trolled the city official, saying: “We’re all out there looking for it, our eyes are trained on the sidewalks as we walk so as to avoid that awful squishy feeling.”

It looks like the news is coming at just the right time, as around 65 complaints regarding sidewalk poop are made by San Francisco residents every day. Notably, the city, which is known for its skyrocketing housing prices, has only 22 public toilets.

Being part of a multi-million effort called Pit Stop, the toilets are open only until late afternoon or evening. So, at nighttime, there is only one option for homeless people to relieve themselves when urgently required.

Some of the waste also comes from dogs, as their owners fail to pick up after them.

Doing everything we can to make sure sidewalks are clear for pedestrians. pic.twitter.com/iRH3ZITOWg
— Mohammed Nuru (@MrCleanSF) August 13, 2018

Don’t understand why people trash our beautiful city. Please call 911 if you see people dumping. Whomever did this should do some time in jail. pic.twitter.com/aqMUMpPZWN
— Mohammed Nuru (@MrCleanSF) August 13, 2018

Mayor London Breed had been taking unannounced tours to check out the city’s streets before she teamed up with Public Works to establish ‘Poop Patrols.’ Breed said she had “to deal it with myself in front of my home,” which was “not a pleasant feeling.”

Earlier this year, residents pounded city authorities with demands to remove “sh*t, poop and excrement” from public areas. “[A] homeless encampment is blocking [the] sidewalk and creates a health hazard [with] trash and feces. Please move them, and send a cleaning crew. Sidewalk is impassable, forcing pedestrians into the street,” read one municipal complaint.

Photo shows ’20 pounds of feces’ dropped on #SanFrancisco sidewalk 😮💩 https://t.co/vMmr75CFumpic.twitter.com/06RNHQaN8h
— KRON4 News (@kron4news) July 2, 2018

The scale of San Francisco’s human-waste problem was graphically illustrated back in July, when photos of a sizeable plastic bag of excrement that was abandoned on a street corner were circulated on social media.

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A homeless person in San Francisco / Getty Images
https://www.rt.com/usa/431838-san-francisco-human-feces/

Tech hub San Francisco, California is the second-most expensive US city to live in. It’s also awash with human waste. This year, over 16,000 feces-related complaints have been lodged with city authorities.

As of Thursday, there have been 16,022 complaints made about ‘feces,’ and thousands of others made using words like ‘sh*t’, ‘poop’ and ‘excrement’, to San Francisco’s municipal authorities.

“Human feces still not cleaned up despite multiple complaints. How many weeks will pass?” reads one complaint lodged Wednesday.

“Bodily fluids and feces down the whole street, garbage, cloths, food thrown all over sidewalk,” reads another.

“Homeless encampment is blocking sidewalk and creates a health hazard w trash and feces. Please move them, and send a cleaning crew. Sidewalk is impassable, forcing pedestrians into the street,” reported one user, his complaint accompanied with a photo of a tent pitched under a tree in the city’s central Mission district.

San Francisco residents can make non-emergency ‘311’ municipal complaints with the touch of a button, thanks to a website and a mobile app. Complainants can attach photos as proof, and the authorities send a notification when the problem is resolved.

Many of the complaints are connected to the city’s homeless problem. Rent in the city averages over $3,500 per month, pricing out all but the highest earners and creating a city of wealthy tech employees on one side, and a teeming homeless underclass on the other.

San Francisco is beautiful, just don’t mind the giant bags of feces and step over the used hypodermic needles!
— E.Stanley Thurston (@mrgoody_2_shoes) July 4, 2018

There are an estimated 7,500 homeless people in San Francisco at any given time, almost one percent of the city’s 871,000 population. Elsewhere in California, the problem is almost as grave, with more than one quarter of the US homeless population living in the state.

The city’s seedy underbelly leaves behind other forms of hazardous waste too. A February NBC report revealed that in addition to feces, downtown San Francisco is polluted with more garbage and used syringes than some of the world’s poorest slums.

Dr Lee Riley, an infectious diseases expert at the University of California in Berkeley, told NBC reporters that in some parts of the city, the contamination is “much greater than communities in Brazil or Kenya or Italy.”

Getting stuck by a used needle can pass on diseases like HIV and Hepatitis B and C. San Francisco has one of the largest HIV-positive populations in the US, with an estimated 16,010 people living with the disease.

Disturbing survey finds trash, needles, feces littering streets of Nancy Pelosi’s home town. San Francisco has streets covered with garbage, human excrement and hypodermic needles across the liberal city. Discarded needles could cause HIV and Hepatitis B and C, Paradise lost. pic.twitter.com/UVcYL90ZdQ
— Captain Ron (@papaneeed1) June 16, 2018

The extent of San Francisco’s human waste problem was graphically illustrated last week, with photos of a 20-pound bag of excrement abandoned on a street corner going viral. The city received several 311 complaints about the bag, as citizens reported a “strong smell of feces” in the area. One reddit user described the bag as “the most atrocious smell I’ve ever smelled in San Francisco.”

Photo shows ’20 pounds of feces’ dropped on #SanFrancisco sidewalk 😮💩 https://t.co/vMmr75CFumpic.twitter.com/06RNHQaN8h
— KRON4 News (@kron4news) July 2, 2018

Complaints about human waste in San Francisco have skyrocketed, increasing by 400 percent from 2008 to 2018, according to the City. The 311 site and app received over 21,000 reports last year. At the current rate, that figure will be more than doubled by the end of 2018.

The problem is starting to hit the Golden Gate City where it hurts too. This week, a major medical association decided to pull its annual convention out of the city, citing safety concerns.

The convention was expected to draw 15,000 attendees and bring $40 million into the city’s economy, but organizers told the San Francisco Chronicle that members were afraid to walk the streets and felt threatened by open drug use, unchecked mental illness, and threatening behaviour from the city’s vagrant population.

Twitter users have not been shy about their disgust with the city’s problems, with many blaming years of Democrat leadership for allowing the problem to fester.

San Francisco has reached critical mass in the drug, homeless, crime problem. Now major conventions are cancellingc. Participants too afraid to walk alone in the City by the Bay. So sad. Such a beautiful city being run into the ground.https://t.co/GGtecdpY6f
— Kari Lake Fox 10 (@KariLakeFox10) July 4, 2018

How’s that liberal paradise California @TankTopArms? Anyone ready to #WalkAway? Or do they love being taxed to death and the smell of feces? Is the plan still to secede? #CalExithttps://t.co/egB13LzESZ
— DQ 🇺🇸 (@DQuesada) July 4, 2018

San Francisco is actually a pretty nice city…

You know when you remove the large number of homeless camps, drug addiction, poop maps, and trash lying everywhere. pic.twitter.com/bMr0m2Nk4P
— Ashton Whitty✨ (@ashtonbirdie) July 4, 2018

I’m sitting by the dock of the bay, watching the poo roll away | https://t.co/u7aTOMTjnl
— Mike (@Doranimated) July 5, 2018

San Francisco has grappled with homelessness since the 1970s, with the shortage of housing, deindustrialization, welfare cuts, and the gutting of the city’s middle class through high taxes and gentrification all getting blamed for the problem. Attempts to fix the situation have thus far proven unsuccessful. The temporary shelters opened by Dianne Feinstein in the late 1970s were underfunded and buckled under demand, while the aggressive crackdowns of Frank Jordan and Willie Brown in the 1990s and 2000s drew public backlash and alienated the city’s liberal voters. The city has not had a Republican mayor since 1964.

Recently elected Mayor London Breed has faced even more urgent calls to address the issue before business and tourism are scared away for good. Industry leaders have encouraged the mayor-elect to increase police patrols, enforce panhandling laws, and fund mental health services. With tourism bringing in some $9 billion dollars per year, failing to clean up the streets could bankrupt the city by the bay.

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Revealing the True State of the Nation

SOTN: Alternative News & Commentary
Revealing the True State of the Nation
https://s25.postimg.cc/oqocvxsgv/Trump-media.jpghttp://stateofthenation2012.com/?p=90049

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Trump has only ONE response to the ongoing soft coup being run by rogue elements within the U.S. Intelligence Community
Posted on November 29, 2017 by State of the Nation
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A Military Response

State of the Nation
“President Trump is facing a full-blown coup d’état, sooner or later.
The treasonous co-conspirators are setting up the country so as to
spring into action on several fronts. When they execute the final
putsch will be determined more by sheer desperation than anything
else. They really don’t want to overthrow Trump violently, but will
eventually feel the absolute necessity to do so. This will be their only
way to stay out of prison. Here’s the real problem for the POTUS:
He can only trigger a military solution when all of his ducks are in a
row. Should Trump act prematurely, his success will be put in jeopardy.
Should he act too late, his administration will be in grave danger.”

— Former U.S. Military Officer and Intelligence Analyst

For those who are unaware, the Trump administration has been the target of a slow motion coup d’état sometimes referred to as the Purple Revolution.

BEWARE: The Purple Revolution Comes To America…
…Courtesy of George Soros, the Clinton Crime Family, and the Obama Administration

Most of the leaders of this stealthy insurrection are unknown and working deep within the U.S. Intelligence Community. Others, such as former CIA Director John Brennan, former Director of National Intelligence James Clapper, former Director of the National Security Agency, Principal Deputy Director of National Intelligence, and Director of the Central Intelligence Agency Michael Hayden, as well as former CIA Deputy Director and Acting Director Michael Morell are highly visible leaders of the coup faction.

However, it is the countless agents of Deep State who populate the Zio-Anglo-American Intelligence Community that pose the real problem. In this regard, it’s virtually impossible to determine who is really serving the POTUS, and who is working against him. Because the U.S. intelligence agencies have been systematically ponerized since day one by the C.I.A., who and what is not effectively owned and operated by The Company, as it’s known by spooks everywhere.

The C.I.A. Literally Controls EVERYTHING … Even Deep State

Inasmuch as the C.I.A. completely controls the Mainstream Media (MSM), they have conscripted all of the largest news outlets to attack Trump 24/7. Likewise, the C.I.A. has enlisted the aid of every major globalist organization in the world to take down Trump. You name them: the Council on Foreign Relations, the Bilderberg Group and the Trilateral Commission. The Committee of 300, The Royal Institute of International Affairs and the United Nations. The reality is that the full weight of the all-powerful Round Table is stacked heavily against the Trump Administration.
What’s the point?

Add to the truncated list of power-players above all the secret societies and think tanks, NGOs (esp. Soros-funded) and Fortune 500 Companies, and the challenges become even more formidable. Particularly when you consider the pervasive influence of Silicon Valley and Hollywood that is squarely aimed against him, does Trump’s predicament come into sharp relief.

The salient point is that the entire System has assumed an extremely aggressive posture toward the POTUS. Hence, Trump is compelled to formulate a counter-coup game plan that is infallible. He has absolutely NO wiggle room between his rock and hard place. And, there is no precedent for him to consider for comparison’s sake. History provides absolutely no parallel to Trump’s plight in 2017/2018 on planet Earth. (The Internet has created a whole new universe known as cyberspace where this war is really being fought.)

What Team Trump does have is Sun Tzu’s classic — The Art of War — to consult. There’s no question that The Donald is regularly applying some of the most effective strategies and tactics imparted by that ancient Chinese military treatise. For example:
‘If your opponent is temperamental, seek to irritate him.’
— Looks like the Trump playbook has borrowed from Sun Tzu

However, in order to decisively take down the Deep State and terminate the Central Intelligence Agency, Trump will have to think through every single part of what will have to be a perfectly controlled demolition. This can only be achieved by utilizing all 5 branches of the U.S. Armed Forces.
Why have there been no arrests?

Many throughout the truth movement (and especially the Trump movement) have questioned the lack of arrests of known traitors. Everyone now knows who has committed acts of naked treason against the American Republic. And, yet, no one has been taken into custody or even indicted. Many are also aware of the horrific crimes being committed regularly against our children by the same bad actors. And in Washington, DC, no less!

PIZZAGATE: A Special Report on the Washington, D.C. Pedophilia Scandal

Any such move – mass arrest of the traitors – can only be conducted when “everything is in good order” since it will immediately precipitate a severe reaction from Deep State. Their (TPTB) predictable and overwhelming self-protective response could range from anything to anything. Yeah, that’s just how volatile and precarious this situation has become, and it’s rapidly intensifying by the week.

The practical reality is that the longer that Trump is in the Oval Office, the more time he has to acquire the necessary intelligence on every single conspirator who is participating in the Purple Revolution, past and present. With this vital data, he is able to simultaneously arrest all the plotters and decision-makers, as well as the numerous insurrectionists on the ground and their mid-level handlers.
Extreme polarity precludes a political solution

The entire Democratic Party (especially the DNC); the Soroses, Clintons, Obamas, Bidens and Podestas; the sultans of Silicon Valley; the Hollywood moguls; the East Coast intelligentsia; the MSM organs of propaganda; as well as many rogue elements in the C.I.A. basically pushed this situation beyond the point of no return. All of these collaborators have worked assiduously to cultivate an environment of “Us versus Them”— nationwide.

By perfecting the dark arts of identity politics and the cult of personality (e.g. Obama and Hillary), they succeeded in dividing the body politic as never before. The myriad social justice warriors have likewise exploited the vulnerable demographics to the point where the various wedge issues forever divide the American people. As a result, there appears to be no common ground to stand on anymore and, therefore, no space for reconciliation.
Civil war must be avoided

The grim reality is that the nation now finds itself in the midst of a civil war. Very few are aware of the gravity of the current state of affairs, but that’s where we really are. The cold phase always pre-dates the hot one. Nonetheless, if bold measures are not taken with all deliberate speed when necessary, there will soon come a time when the hot phase will rear its ugly head. The truth be told, the Las Vegas mass shooting was actually a stealth attack on the patriot movement by the Left. Country & Western music festivals are basically congregations for the Right. Those Route 91 HARVEST concert-goers were ambushed in cold blood.

For the good of the Republic, President Trump will be compelled to take action against the many traitors throughout the U.S. Federal Government, state governments and municipal governments. Whenever the barbarians are already inside the gate as they are now, there is only one alternative; they must be exposed and prosecuted for their crimes against the American people. Toward that end, Trump will be required to shut down the existing MSM (and take them over) among implementing several other radical initiatives which deny support (both material and moral) to the seditious criminal activity of these Bolsheviks.

There is no other way to tame a Bolshevik than to bust them upside the head with a four by four. That’s the only language they understand, as Black Lives Matter and AntiFa have clearly demonstrated. The liberals have become ultra-liberal, the lefties have transformed into left-wing extremists, and progressives have morphed into hyper-progressivism so that there is no more middle ground—anywhere.

Cultural Marxism must be defeated

Those blue states that have Democrat-dominated statehouses, and big cities with Democratic mayors and city councils, provide graphic examples of where things have gone. When the once great state of California has gone to hell in a handbasket, you know the writing is on the wall for the United States of America…unless the inexorable advancement of Cultural Marxism is short-circuited post haste. Only the POTUS can do that in the manner required.

Many have now come to their senses and understood that the USA is in serious trouble. The US government is totally dysfunctional, Corporate America is poised to experience a replay of the recent Great Recession, and civil society collapses by the day. All of these developments are directly due to the unrelenting promotion of Cultural Marxism by the power elite. They know that their place at the very top is secure when American society has sufficiently eroded, order has been replaced by chaos, and the economy is unstable.

Trump’s most difficult challenge will be to ferret out those in positions of authority and influence who laud the nation’s incremental metamorphosis into a modern-day “Sodom and Gomorrah”. This extremely thorny and knotty obstacle alone appears to be insurmountable. And it just may be. Nevertheless, the only way through this period is to effectuate a sweeping change in leadership across the board. Only in this way can the Cultural Marxists be permanently removed from power.

The following article provides important background, the understanding of which is integral to reversing this perilous trend. How Cultural Marxism was used to create an American “Sodom and Gomorrah”

Special Note:
There is only one way that President Trump can push the button on a military solution. There must be a critical mass of law-abiding patriots who stand solidly behind him. Whereas the agents of Deep State still control and/or influence much of the national security apparatus, levers of government and judicial machinery after 8 years of Obama stacking the deck, the Right controls the land. The rural country of America is as red as Georgia red clay, so the food supply and its transportation (Trump truckers) are exclusively controlled by the Right. They also comprise a great majority of military, ex-military and militiamen, as well as the police and sheriffs most of whom are also gun owners and hunters. The crucial point is that, as Commander-in-Chief, Trump not only commands the Armed Forces directly, he also exerts much influence on those patriots who will show up for battle should it ever come to that. The C.I.A. apparently underestimated, to a great degree, just how much leverage the POTUS really has, specifically a populist president who is also a real nationalist. As they say in the Deep South, whoever has the biggest dog, wins the fight. And there ain’t a bigger DOG inside the Beltway than Donald J. Trump.
Pizzagate & Pedogate

Trump has two trump cards that he’s holding close to the vest.

Each of them provides the one-two punch necessary to take down the NWO globalist cabal, both at home and abroad.

Pizzagate will take down the Washington political establishment, corrupt Democrats and Republicans alike. Pedogate will overthrow the exceedingly powerful forces that are projected from London and Rome, Brussels and Paris, Tel Aviv and Riyadh. The almighty Black Nobility, in particular, will be weakened sufficiently so that Operation Gladio can be rendered ineffectual.

Once this all-pervasive control mechanism — Pedogate — is completely dismantled, Presidents Trump and Putin will be able to jointly pursue the common goals they so desire. However, it is D.C.’s own Pizzagate that will give Trump the leverage required to demolish Deep State and “splinter the CIA into a thousand pieces and scatter it into the winds”. PEDOGATE: Pandora’s Box Has Been Opened for Deep State and the C.I.A.

Perhaps the only legal context in which both Pizzagate and Pedogate can be prosecuted is the Uniform Code of Military Justice. That’s because the Criminal Justice System, and particularly the judiciary, are mainly made up of dyed-in-the-wool Democrats. Hence, the absolute necessity for military tribunals to be formed to handle the imperative prosecutions that will incarcerate the prime movers of the Purple Revolution. Subsequently, a national Truth and Reconciliation Commission can be established to judiciously process the multi-decade crime spree perpetrated by the wealthy and political elites on We the People.

KEY POINT: Perhaps the Guantanamo Bay detention camp was really built for the many high-level American officials and politicians who have betrayed their country over decades. This is why the only solution for Team Trump is a military one. Those leaders, who have been relentlessly controlled and manipulated by way of Pizzagate and Pedogate, can only be incarcerated in tightly guarded military prison; otherwise, they will be murdered with great haste. The true perps behind the Pedogate control mechanism will stop at nothing to destroy the evidence, and especially to eliminate the witnesses. After all, the Clintons and Obamas, Bushes and Bidens are merely low-level and expendable pawns in a very dangerous and deadly game.
Conclusion

President John F. Kennedy said it best:

State of the Nation
November 29, 2017

Editor’s Note

PEOPLE OF AMERICA: In the absence of a profound and fundamental transformation of American society, the USA will continue its descent into the abyss of Cultural Marxism. The cultural elites are hellbent on preserving their hard-fought “Sodom and Gomorrah”. They will not give up their utter depravity easily and will clutch it until their dying breath. Therefore, everyone is highly encouraged to do their part to resist the moral depredations which flow from Cultural Marxism—an inherently flawed and degrading philosophy of living. All that has to be done is to starve the BEAST. If you don’t feed it, it will die.
“When one has nothing else to lose,
the predator becomes the prey.”

*Permission is granted for reposting this article in full with a link back to the original SOTN post.

___

Trump has only ONE response to the ongoing soft coup being run by rogue elements within the U.S. Intelligence Community

Turn Them Off! #QAnon and the collapse of #FakeNews media

Turn Them Off! #QAnon and the collapse of #FakeNews media
By Editor August 8, 2018 1 Comment
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http://www.theeventchronicle.com/intel/turn-them-off-qanon-and-the-collapse-of-fakenews-media-2/

The scientist is not a person who gives the right answers, he is one who asks the right questions.

Claude Lévi-Strauss

By Martin Geddes

We are at war. Until now it has been a shadow conflict, conducted largely out of sight of the public. In the last few weeks it has begun to unmistakably break through into the open. There is nothing else in the tech-telecom world that comes close to it in importance, which is why I write about it in preference to everything else. To pretend otherwise would be a dishonourable act of omission.

This war is for the most important territory on the planet: your mind and spirit. It is a real war, being conducted by the formal military against a highly organised opponent. The enemy is not a foreign country, but instead comprises traitors and criminals in our midst. Whilst it has a traditional kinetic component — bombs, lasers and drones — its defining weapons are memetic. Surveillance, counter-intelligence and propaganda are the new longbows, armour and missiles.

Longstanding readers will know that I am not stupid or silly. Being human, I have the occasional foolishness or misadventure, but my intellect and integrity are both fully intact. There is a good reason why I am forcefully presenting things that may make you feel uncomfortable: there is going to be no way of avoiding these matters in the very near future. Everyone is going to be confronted with diametrically opposing narratives, and will have to make a choice over which one to believe and act upon.

You are likely to have seen one of the many articles in the mainstream media in the past week on #QAnon. Each one of them warns you of how this is a “dark”, “right-wing” and “dangerous” movement. The loaded term “conspiracy theory” is used over and over, warning you of the shameful and fearful social consequences of being associated with this movement.

My position is well known: Q is instead a military operation by “white hats”against the corrupt and criminal “deep state”, being led by the NSA and Marines. The mass media has been infiltrated and compromised for decades, being used as a tool of social control. The #QAnon programme is a fifth-generation warfare technique to destroy the credibility and power of the #FakeNews media.

This has come to a head because at the Tampa rally, Trump supporters were allowed to bring in placards, which are usually banned for safety and security reasons. Many of them included messages about Q and WWG1WGA. This forced the hand of the media to cover the story, since further ignoring it would be such a telling silence that it could awaken the sleeping masses.
Here are some questions I would like you to ponder, so you can decide for yourself which way the truth might lie.

1. Why has not a single one of these media organisations asked President Trump whether Q is legitimate, since this would immediately resolve the matter for everyone? How do you account for this journalistic lapse in elementary data gathering before publishing a story slurring such a large group of ordinary people?

2. Why do they not cite or rebut Q’s drops, as would be normal journalistic practise in disproving something of factual debate? If they are self-evidently false, this should be trivially easy. Why do you think they refuse to engage on the facts, but offer emotive innuendo in its place?

3. Why is there no mention of the 45,000 sealed indictments (50x growth over normal), signifying impending mass arrests? This is a matter of public fact and record — as are the unprecedented CEO resignations (very few being rehired…) and politicians withdrawing from office. What’s your hypothesis for this omission?

4. Why is there no concomitant coverage of the significant increases (5x over past) in arrests and convictions for human trafficking and child pornography, yet there are constant protestations that widespread “elite” paedophilia (aka “pizzagate”) is a “debunked” matter? The press coverage of the sensational NXIVM cult trial — implicating those close to the Clinton Foundation with child sex slavery — is spectacularly muted. How do you account for this silence, given what Q tells us?

5. Why are the dozens and dozens of strong links between Q and the Trump administration given no credence? (Here are 45 for you to begin with — this would easily get you beyond the standard of proof for a court case.) Q encourages people to think for themselves, whereas you are being told by the MSM what to believe and ignore the evidence in front of your own eyes. How do you make sense of this data not being presented to you?

6. How come none of these organisations deemed #QAnon newsworthy before the Tampa rally, yet it is a movement that is suddenly threatening to the wellbeing of democracy and society? How do you account for this timing and the coordinated message using identical terminology? (Although apparently following Q is simultaneously “fringe” and “wildly popular”!)

7. These same organisations overwhelmingly supported Hillary Clinton for President, and wrongly predicted her win right up until the last minute. They have widespread and documented links to the Democratic party, both legitimate (as donors) and illegitimate (illegal and unethical relationships documented by Wikileaks). Are they dispassionate reporters of fact, or active players in the political game attempting to shape the narrative? How might it affect their reporting on Q?

8. Given that these media reports make many basic factual errors, are they credible journalism? Here’s one (from the Guardian):
Turn Them Off! #QAnon and the collapse of #FakeNews media

Q has never posted on Reddit. Does this suggest familiarity with the subject matter, or profound ignorance?
You are very soon going to have to decide whether these media organisations are involved in transnational criminal racketeering, and collusion with mafia-like entities embedded into government. It will only take a single tweet from President Trump — flagged up by one of Q’s first messages — to end the debate. This single message would destroy all these yellow journalists, forever:

This would explicitly confirm that Q is an agent of the Trump administration. At that point every single damning article about Q as a “conspiracy theory” becomes a perpetual condemnation of its author and publisher. Such confirmation could come in many other forms — this being just one possibility. The #FakeNews media trap has been set by Q, the bait has now been taken, and the gory denouement is approaching.

That moment of reckoning is inevitable, even if I cannot predict when: today, this week, this month, or even later in the autumn. It is a “slow walk” leading up to the US mid-term elections, and you never reveal your plans to the enemy in advance. The worst will doubtless be revealed close to that November date for maximum destructive impact. The #FakeNews media is being given adequate time to manufacture the rope by which it will send itself to the gallows of infamy.

I believe that you are seeing a carefully scripted military operation play out. The mass media’s audience is an active part of the direction of the play. In this spiritual fight against evil masquerading as virtue, everybody is on the information warfare battlefield, like it or not. The next few weeks and months promise to be quite a ride. As Q has stated 28 times so far: “enjoy the show”.

This is not a game, it is the real deal. You have a responsibility to yourself and your family to make good choices. Consider my questions very carefully. Imagine how criminals working to usurp your freedom and security would act if they controlled the mass media. Who do you think is telling the truth, when nobody else tells you what to believe?

Listen to your heart for the answers, for it cannot ever lie.

Legitimate journalism, or mafia media threat against free-thinking patriots who resist their social and mind control techniques?
Related content

You may also enjoy the following related content that I have produced.

WWG1WGA: The greatest communications event in history—50,000 readers can’t all be wrong!
The silence of the sheep — giving hard evidence the media isn’t telling you the whole story.
The Great Awakening: Its impact on the tech industry — an introduction to the idea “something big is happening all around us”.
Making sense of #QAnon and #TheStorm — title speaks for itself — with the follow-up of Q is Military Intelligence.
Treason and text messages: whom to trust and what’s the truth?—heuristics to separate fallacy from facts.
My experience of Twitter censorship—creepy editing of reality by the social media giant.

About Martin Geddes

I am a distributed computation expert, network performance scientist, and consultant to telcos and their vendors.

I collaborate with leading practitioners in the communications industry to create game-changing new technologies and businesses.

Get in touch if you need a thinking partner, inspiring speaker, workshop magician, or strategic advisor. I also offer education in network performance, digital supply chain quality, and the future of the Internet.

More about me in my professional guise: martingedd.es
About my consulting company: http://www.martingeddes.com

Follow @martingeddes on Twitter. I am also on Gab as a backup plan.

This article was originally published as a Future of Communications newsletter.

This article (Turn Them Off! #QAnon and the collapse of #FakeNews media) was originally published on Medium and syndicated by The Event Chronicle.

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California mayor escalates ‘sanctuary city’ war, and Sessions returns fire


California mayor escalates ‘sanctuary city’ war, and Sessions returns fire
By Brian Lonergan, opinion contributor – 03/16/18 10:00 AM EDT
http://thehill.com/opinion/immigration/378711-california-mayor-escalates-sanctuary-city-war-and-sessions-returns-fire

It is becoming increasingly difficult to deny the obvious: when it comes to immigration policy, there is a de facto cold war being fought between the state of California and Washington, D.C.

Libby Schaaf recently fired the first shot.

If California vs. D.C. is a cold war, Mayor Schaaf’s actions threaten to make it a hot one. Until now, California’s defiance of federal law has been mostly passive. The Golden State presently has 35 communities that have proudly enacted sanctuary policies to protect illegal aliens from federal immigration authorities. California’s SB 54 went into effect at the start of the year, officially banning local officials from asking about a person’s immigration status. Schaaf’s disclosure represents a much more proactive form of rebellion.

The feds are not amused. Last week Attorney General Jeff Sessions announced a lawsuit against the state, charging that SB 54 and two of its other immigration laws violate the Supremacy Clause. Before an audience of law enforcement officers in Sacramento, Sessions unloaded on Schaaf while adding that he recently signed condolence letters the previous day to the families of two law enforcement officers killed in the line of duty.

“Here’s my message to Mayor Schaaf: How dare you?” said Sessions. “How dare you needlessly endanger the lives of law enforcement officers to promote a radical, open borders agenda?”

Acting ICE Director Thomas Homan likened Schaaf’s actions to that of a “gang lookout” and said that more than 800 criminal aliens were able to escape the raid as a result of her warning. Homan has long insisted that by prohibiting state and local officials from cooperating, ICE agents are forced to deal with illegal aliens at their residences and other places that increase the danger to both sides. Homan and others have suggested that Schaaf and politicians who act similarly should face obstruction of justice charges.

In damage control mode, Schaaf issued a statement in which she proclaimed, “I know that Oakland is a city of law-abiding immigrants and families who deserve to live free from the constant threat of arrest and deportation.”

That statement explains a lot about the disconnect between open borders politicians and reality. In the upside-down world of California politics, illegal aliens are “law-abiding immigrants,” even though their very existence in the country constitutes a violation of federal law. Along the same line of thinking, those who break our immigration laws deserve to “live free” from any accountability for their actions. This is lunacy and shameless political pandering. Far down the mayor’s list of priorities, apparently, are the real law-abiding citizens of her community who still have more than 800 convicted criminals roaming free among them who should not be there.

While the immigration issue inspires enough passion on its own, California’s extreme position on it is tearing at the very fabric that holds our republic together. The precedent set here is an ominous one. What other federal laws may California decide tomorrow should no longer apply to it? What if numerous other states decide to follow their lead? Instead of immigration laws, what would be the effect if states chose to ignore federal laws on, say, firearm purchases, abortion or same-sex marriage? The result would be nothing short of chaos. The slippery slope here is steep, and California is willfully hurtling down it at breakneck speed.

Schaaf and others like her are doing great damage to the country. They are undermining the rule of law and encouraging illegal activity. Those who act out of such political expediency are putting their constituents, both citizens and illegal aliens, at risk. States should not be in open rebellion to the federal government on matters of national security. Like most wars, this one is not likely to end well for anyone.

Brian Lonergan is director of communications at the Immigration Reform Law Institute, a public interest law firm working to defend the rights and interests of the American people from the negative effects of mass migration.

From 2015: The Pacific Ocean is Dying

Pacific_ocean-e1439274339593
free image uploading

Peter Daley August 2015,

The Pacific Ocean Is Dying!

A huge amount of radioactive contamination, conservatively equal to 10,000 Hiroshima nuclear bombs, has been released from the Fukushima Nuclear Catastrophe site. The Fukushima nuclear catastrophe site is still releasing huge amounts atmospheric radioactive contamination, plus thousands of tons of highly radioactive contaminated water is still flowing into the Pacific Ocean every day!

There are an increasing number of media reports coming in, of Pacific Ocean fish, whales, birds and other sea creatures dying in large numbers. The Fukushima radioactive contamination would be lowering the fertility and weakening the immune systems of any sea life coming in contact with it. As immune systems become weakened, it would be logical to expect viruses and bacteria that would normally be under check, to become more infectious. This radioactive contamination could also potentially stimulate viruses and bacteria to mutate into more infectious strains.

This massive amount of radioactive environment pollution has resulted in the Pacific Ocean food supply crashing! Like the human embryo, embryonic sea life including fish eggs, are hypersensitive to radioactive contamination, hence the large number of reports of seals, whales and birds etc., washing up on the west coast of North America, starving to death.

Thanks to Dr. Sternglass, for this research paper below. It clearly demonstrates how nuclear contamination from the nuclear bomb testing era caused a significant crash in Pacific Ocean fish stocks. If this was the case then, it would be logical to assume that the Fukushima Nuclear Catastrophe is having a similar effect.
Quote:
“The purpose of the study was to determine whether continued atmospheric testing by France and China or potential releases from underground detonations that might unexpectedly escape into the nearby fishing grounds could have detectable effects on the reproduction of fish populations similar to the unanticipatedly severe effects of low level radiation on the human embryo and fetus (2, 3, 4) recently confirmed by independent studies by other investigators (5, 6).”

08.10.1971 – Fallout and Reproduction of Ocean Fish Populations. E.J. Sternglass, Department of Radiology, School of Medicine, University of Pittsburgh, Pittsburgh, Pennsylvania

Extract:

Nuclear Fallout causes Fish Population Decline,

As will be shown below, very large declines of fish-populations after low-altitude nuclear tests followed by a gradual recovery to pretesting levels have been observed both in the Atlantic and Pacific, strongly suggesting that the eggs of fish and the developing young are far more sensitive to internal radiation from low-level fallout than had been anticipated, very much as in the case of the human-embryo and fetus.

http://www.mindfully.org/Nucs/Fallout-Fish-Sternglass8oct71.htm

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