Rico-Final 738 Pages, 3-28-17, 11pm

1 PLAINTIFF REMINGTONS RICO STATEMENT- JANUARY 2017
I. Introduction:
2
A. Brief Background. Defendants buried about 2 million pounds of illegal contaminated,
3
ultra-hazardous wastes on Remingtons land in 1998. This RICO case is about the criminal
4
enterprise formed by Gans and his co-conspirator lawyers to force Remington to keep those
5
contaminated toxins, stop his lawsuits to remove them, and to shut-up, or suffer grave
6 consequences. Today, Gans RICO enterprise is most fundamentally an extortion protection
7 racket, under 18 USC 1951, which for years has violently, continuously and destructively
8 attacked Remingtons business property, large estate and gardens, and then Gans promised he
9 would call-off his soldiers and protect Remington from further damage if he gives up his
10 encroached land, contamination lawsuits and leaves the area.
11 Defendants have alleged that around 1998, RAO construction approached the Mathsons about
permanently storing millions of pounds of hazardous, contaminated gas station remedial, lead and
12
asbestos wastes on their property and adjacent to it, well into Remingtons redwood forest.
13
Defendants short-hauling scheme, as explained below, produced vast overall illicit and
14
UNJUST profits in the seven figures range. Accordingly, RAO located, illicitly contracted for,
15
hauled, dumped and then illegally buried about 4000 yd (400 10-yard dump loads) under
16 meticulous landscaping, in dense redwood forests on both beautiful residential properties.
17 Defendants admitted toxic, trespassing encroachment onto Remingtons land with more than
18 600 cubic yards of hazardous, toxic, buried and concealed unwanted materials was discovered by
19 Remington in 2006, and Remington filed suit in 2008 for removal by defendants insurance
20 company, under California and federal environmental contamination, trespass and nuisance laws,
21 which case continues here.
Although defendants legal defense has always been highly aggressive, VERY unethical and
22
an at least partially corrupt from its inception, it was not originally criminal in its scope and
23
implementation. The initial hazardous dumping crimes were illegal and violated many federal, state
24
and county environmental laws, John Mathson was even seen hastily leaving the scene of an arson
25
of Remingtons primary structure in 2008, plus there were other frequent acts of vandalism
26 attributed to RAO, Mathson and his local gang over the years, but those earlier incidents were
27 largely ignored and handled easily when Remington was younger and stronger. Nevertheless, in
28 retrospect, they formed a logical background for this federal RICO action.
REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

1
Because the contaminants were at least 99% buried, invisible, undiscovered and/or
1
undetectable until excavated in 2006-2010, no damages at all were visible or foreseen, and no
2
causes of action were ripe or contemplated. Here, as a successive action continuation of the
3
2008 lawsuit, remediation costs are requested initially for the three prior years, under applicable
4
California and federal continuing trespass, nuisance and environmental law. As discussed below,
5 damages under Renz and for several other three-year periods, or through trial and appeals, are
6 somewhat more complex.
7 B. The Racketeering Influenced and Corrupt Organization (RICO) Act violations alleged
8 herein probably did not provably began until December 2012, and although many other corrupt
9 state law violations occurred earlier, and arguably even several in the original federal case, CV 09
10 4547 NJV, from 2010-14, provable federal predicate acts have have continued and exploded
exponentially since 2012. Today, we immediately need 60-90 days of federal discovery which as
11
explained in the footnote below will most likely END this case before it even gets started, for the
12
reasons explained1.
13
Today, defendants criminal enterprise is clearly visible and is led by The Godfather-like
14
figure Russell Gans, Esq. with able and strong support from his law partners Paul Brisso, Ryan
15 Plotz, Kloeppel and able researcher and executive office manager, Julie McBride.
16 Gans now leads a racketeering enterprise of at least 32-40 specifically named defendants,
17 soldiers, and associated other presently non-named defendant members. Gans and his law
18
1
Michaels v. Ameritrust, 848 F. 2d 674 (1988, 6th C) authoritatively teaches that in order to properly allege all
19 information with respect to defendants past and present frauds, discovery must be permitted in order to
20 discover and produce the extensive information which is only within the opposing parties knowledge and control,
citing numerous cases which say that dismissal is improper and unjust where a plaintiff has unfairly been denied
21 the opportunity to obtain that information regarding frauds and crimes, which is solely under defendants control.
Remington hereby challenges Gans and all of his Mitchell co-conspirators and enterprise leadership to DENY
22 now under oath all allegations made in this RICO statement, especially those involving 1503, et seq, and
1511-1513, 1515, which generally-speaking involved false statements, perjury, obstruction of justice and
23 witness tampering in the 2016 SOL trial. In other words, defendants now must reassert in this federal forum that
all of those state facts are absolutely true as falsely sworn to in 2016. However, since we all know that most of
24 that testimony was false, and that eventually that will be proven either before or after several of the enterprise
25 members crack and decide to tell the truth, therefore it is highly unlikely that the leadership in the Mitchell
firm will risk federal imprisonment by repeating all of those 2016 false statements, denials, accusations and
26 related corrupt mischaracterizations, because now in federal court they will generate dozens or hundreds of
federal predicate acts. Why would defendants now risk imprisonment in such a minor case where only their
27 pride is at issue and not a lack of money? Therefore, Remington earnestly and urgently requests that this court
immediately authorize written and oral discovery prior to any decision on dismissal herein, because as explained,
28 defendants are unlikely to be able to defend against this suit on the merits. After that discovery period,
Remington will appropriately amend his complaint shorter and also make his RICO statement more concise and
less repetitive.
2
partners now lead an efficient, highly administratively and legally organized loose association of
1
individuals and small business organizations which has unlimited financial backing from the
2
Mathsons' and Mitchell firms account manager at Allied Insurance, Linda Lawrence. She is here
3
4
sued in her personal capacity only, and not as an insurance company for the reasons described below.
5 C. Gans RICO enterprise has several obvious, known goals and clear objectives:
6 1. To make money and maximize Allieds profits and goal of paying out zero money for
7 Remingtons just remediation, damage costs and expenses. Remingtons requests are just because
8 even in 2011 their low-ball settlement offer was at least $100,000, but that was quickly withdrawn
9 before it could be further negotiated. In other words, if defendants and their insurance company did
10 not realize they were guilty and obligated to remove their encroaching debris from Remingtons land,
why did they offer $100,000, but then unjustly revoke that offer for tactical reasons, after a technical
11
federal summary judgment and the death of Remingtons preeminent environmental expert?;
12
2. To protect and cover-up RAO's and the Mathsons' illegal dumping and concealment acts 100%,
13
so that they both pay nothing and avoid prison. They bank their million+ dollar profits and screw
14
Remington, the neighborhood and the Creek, wildlife and environment. RAO has a separate unknown
15 insurance company, (Allstate?), which is also getting involved here through attorney Kluck;
16 3. To crush Remington and The Burl Tree entirely, until he dies or gives up. That is the central
17 core of Gans RICO extortion protection racket, which again is protection from Mathsons
18 gang and their enterprise soldiers. Remington has about $200,000 in remediation costs and other
19 costs and justified property and personal injuries, and Remington will not be going-away, while
20 still standing. In other words, $275,000-350,000 dollars might resolve all this, but Gans promised
Allied, Mathson, et al that he could win this big, break the personally hated Remington and make
21
him take nothing and like it. In fact, their main goal today is to win 100%, make Remington keep
22
all $200,000 of contamination and then sue him for over $100,000 or so of costs, plus malicious
23
prosecution damages. Winning 100% now appears to involve driving all of Remingtons family
24
away from these sites by making it too nerve-racking, unpleasant and fearful to visit, as explained
25 below;
26 4. They also want to keep all Remingtons land cost and rent-free.2
27
2
As explained thoroughly throughout these documents, Gans wants to erase all of Remingtons claimed
28 damages, which include: The one third acre of Remingtons property directly occupied now by Mathson or
the contaminated land below Mathsons toxic waste dump; defendants dont want to pay the purchase price
for any of that land ruined, or to pay any legally mandated reasonable rent for it; defendants have ruined
3
D. Specific Criminal Activities. How has Gans attempted to accomplish these above goals?
1
1. Until 2012, Gans merrily conducted an unethical hyper-aggressive advocacy for the Mathsons,
2
but when that did not work and making Remington an offer which he couldnt refuse also had
3
failed, so far, he had to improvise and go fully corrupt. In 2016, Gans gave up all pretenses of
4
proper attorney ethics and playing by the rules and winning on the evidence and on the merits.
5 2. Now, Gans ruthless plan being effectuated is to win no matter what it takes, and at the recent
6 2016 SOL trial, Gans carefully coached and suborned blatant perjury in five corroborating
7 witnesses. Actually there was just one BASIC PRIMARY (total) liar (John Mathson) and four other
8 sycophant soldiers who were carefully rehearsed and coached, according to Gans own 2016 Voir
9 Dire statements to: Lie under oath, pretend, and falsely claim that they saw Remington talking to
10 Mathson in 1998 in real time, or heard about it contemporaneously, without actually seeing
Remington at all, or even hearing one lying word. The true facts of these encounters are set forth
11
below.
12
The actual facts and substance of Gans enterprise witnesses testimony are unimportant here
13
and NOT what is complained about. One of the prominent predicate acts so far in this case, was the
14
collusion and conspiracy to actually commit trial perjury in state court. As explained in footnote 1
15 above, it is now unquestionable that Gans RICO members must now consistently repeat that actual
16 provable perjury in the imminent, carefully-crafted federal written Discovery, depositions and then
17 at trial. That will automatically promote Gans collusive, coached, corrupt, multiple state trial
18 perjuries into federal CRIMES with serious prison term penalties attached to each violation, FOR
19 ALL, but especially for the primary ring-leaders: Gans, Brisso, Plotz, Mathson, Skillings,
20 Olson, McBride and Lawrence.
Obviously, several of the other named RICO defendants, e.g. Kishpaugh, Randall, Ferriman,
21
Nelson, etc are also ancillary leaders, at times in their little specialties, and are also criminally
22
culpable to a lesser degree, as are at least 8-10 of the other more subordinate, but nevertheless
23
important enterprise soldiers. Supposedly, if you do (even just) one crime, you do the time,
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even if only as an accessory or consultant.
25
26 Remingtons entire property, invaded and taken over all his gardens and estate and are unwilling to
compensate for that several hundred thousand dollars of damages; defendants dont want to compensate the
27 Burl Tree for the lost land or the lost wholesale burl sales and burl deterioration of more than $350,000, (see
Jagger of Colorado sales documents and 70+ pages of emails) as proven below. Essentially this is a property
28 crime and business crime against the Burl Tree, which owns all the land, the house, garden and all fixtures
and inventory stored therein. Defendants have admitted most of this and its an obvious wrongful, admitted
taking from Remington and the Burl Tree.
4
That said above, collusive state trial perjury, 1503 obstruction of justice in state and 2011-
1
14 federal proceedings, serial witness tampering, bribery, extortion and mail and wire frauds,
2
etc. were among the originally cited 17 different types of federal RICO predicate acts, and most of
3
the 17 were serial violations of 2-100 incidents, which will be proven further, and vastly multiplied
4
during federal discovery, as explained.
5
E. Predicate Acts used in 2017 RICO Cause of Action
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1. 18 USC 1951, Hobbs Act. EXTORTION, deliberately and believably causing FEAR in
7
Remington, the Enterprises most persistent and serious predicate act damaging the Burl Tree;
8
2. 18 USC 201. BRIBERY, at least a dozen incidents of varying severity are alleged;
9
3. 18 USC 1341. Mail Fraud (overlaps with violations of California B & PC 17, 200, et seq);
10
4. 18 USC 1343. Wire Fraud, including internet, email and phone;
11
5. 18 USC 1503. Obstruction of Justice. Gans has no honest scruples or ethics;
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6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor;
13
7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite;
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8. 18 USC 1513. Retaliation Against Witness;
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9. 18 USC 1515 (a) (1,3, 6) & (b), definitions all apply above, such as Making false statements,
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omitting information, intentionally concealing facts and destroying material evidence.
17
10. 18 USC 1952. Barring interstate travel with racketeering or gambling income, BOTH
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applicable here;
19
11. 18 USC 1956. Money laundering crimes, ALL Defendants in this RICO enterprise are
20
guilty;
21
12. 18 USC 1957. Bars property sales and other purchases with laundered, dirty money;
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13. 18 USC 1961-4, et seq. Illegal money laundered profits cannot be invested in businesses;
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14. 49 USC 5101, et seq,. Improper safety permitting and hauling of hazardous wastes;
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15. 15 USC 2607, 2614-15 and 2642. Violations of hazardous materials hauling laws;
25 16. 42 USC 1983, Miscellaneous actionable deprivations of Remingtons rights by defendants.
26 17. 42 USC 102, Drug dealers. Defendants have been observed by Remington and his local
27 witnesses dealing-in, using, selling, growing, manufacturing and distributing Schedule I controlled
28 substances.

5
18. 42 USC 102, ARSON. Allegedly caused by defendants in September 2008, and the REAL
1
FEAR of a repeat at any time, 24-7, 365/year, damaging Remington as below.
2
As per #17 above, Defendants have and are STILL violating 42 USC 102 in using,
3
selling, growing, manufacturing and distributing (cumulatively Dealing in) Schedule I
4
controlled substances, which are chargeable under state law, as per 18 USC 1961 (1),
5 specifically marijuana, amphetamines and opiates, according to several local witnesses.
6
7 As per #18, ARSON. John Mathson was seen fleeing the scene and also observed by two
8 witnesses hanging-around the scene of a mysterious fire of unknown origin only two feet inside
9 an unlocked, unlatched, temporary front door at 832 Westgate Drive, while fire engines were
10 there, on a major fire which nearly destroyed Remingtons $500,000+ structure nearing completion,
which fire very seriously BURNED Remingtons back, as explained, and has led to a great DREAD
11
since and the need to record daily for 8 years every 20-100 pages drafted in these cases at 1-2 day
12
intervals, THOUSANDS of onerous saves of up to 500 drafts of major documents such as THIS
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ONE, to avoid its being lost in the next arson attempt, likely while Remington is away from his
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offices.
15
Remingtons odor (recognizable drug fumes or smoke, sometimes wafting-over from
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Mathsons and Kishpaughs secluded properties) and related anecdotal information and witnesses
17 will be investigated and interviewed further, when time permits during discovery herein, relating to
18 WHICH Westgate GANG MEMBERS, acknowledged long-time drinking buddies, fellow union
19 members, friends and observed non-Westgate residents, RAO workers, Olson relatives, and/or
20 other associated, fraternizing enterprise soldiers were or are contemporaneously involved, in the
21 rather large variety of sorted behavior, and inferential business dealings, which WERE and still
22 are acommon knowledge public nuisance in the neighborhood, especially on summer weekends,
late at night.
23
Defendants have no normal, default good ethical standards at all in any context, and will
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answer for that in due course to the California bar (Section Y, about page 535, below), however,
25
here we have alleged criminality, which can eventually be easily proven with sufficient discovery
26
allowed by the court, after numerous motions to compel over defendants frivolous protective
27
orders, intended to protect their scores of criminal acts. Remington is already drafting a form
28 motion to compel for every special interrogatory and document request.

6
3. Many State and federal criminal laws have been and are being violated now by all defendants,
1
and this civil RICO case is merely the spearhead for and precursor of criminal charges, also being
2
actively pursued (by the time these words are being read) and hopefully investigated by relevant
3
D.A. and/or US attorney criminal authorities, immediately after these documents are filed and
4
served. Beyond any reasonable doubt will be harder on some of these not yet fully discovered
5 allegations, but preponderance should be achievable on many of these charges immediately,
6 especially against all named defendants.
7 ANY individuals that are already specifically named in the complaint can properly infer that
8 sufficient RICO evidence for a federal conviction, for some federal crime, is believed to exist
3
9 already.
10 F. Clearly, Gans is the primary violator of 1962 (c), and the other defendants are
primarily co-conspirators under (d). Most of said co-conspirators would and will follow Gans
11
right off the cliff, as doing what is right and justice have been forgotten here. Happy landing.
12
As described extensively below and in the complaint, RAO, Olson, Mathson and Skillings are
13
known to have reaped enormous, for Humboldt County, unjust profits, and riches, none of which
14
were taxed. Olson, Skillings, RAO and Mathson made under the table cash profits, laundered all
15 that money locally (and beyond as per said discovery and criminal investigations), then they
16 reinvested and co-mingled all those funds for personal use as needed, and then those named above,
17 without limitation, all built known, substantial and valuable residential real estate assets with said
18 funds.
19 Some of those numerous homes were sold, especially by RAO or distributed among family
20 members and employees and also personally used by Olson, Skillings and the Mathsons. False
financial statements and IRS filings were made accordingly, probably ever since 1998 or even
21
before that.
22
However, Remington did not become aware of this secret, concealed scheme, nor did he have
23
a reason to until his additional full investigations of the business aspects of defendants operations
24
during 2014, and subsequently.
25 Remington reasonably relied on all defendants statements and purported legal motions,
26 documents and activities from 2006-2012, but no longer does. Some of the defendants exhibited
27 malice, deceit and knowledge of their 1998 criminal acts, and related unethical coverups since
28
3
As to The city, it is the 1998 Public Works Director, Boyd Davis, which we are after, not the
present city attorney.
7
2008, and Gans has now involved many of his witnesses intimately into the objectives of the
1
enterprise. Said Gans-Lawrence objectives and progressively more criminal activities, especially
2
since 2012, are fully explained in the 500 pages which follow.
3
The Burl Tree, Remingtons business, is Remington, no more or less. This litigation and
4
Remingtons reliance on its integrity and predictability, took all Remingtons time and reduced the
5 Burl Tree business to near zero in most years recently, and always sales of been under $5000 since
6 2006. Specific lost wholesale deals and land sale deals are listed elsewhere particularly in the 2014-
7 15 years, associated with Mick Jagger of Boulder, Colorado. Also any possible county or state park
8 use has now been ended until the contamination problem is alleviated. The biggest single damage
9 involves the 50-75,000,000 gallons of rainwater flowing down Remington Creek annually (or
10 MORE in 2016-17), which Remington could easily capture and pump up to Westgate for under
$50,000. Thats a $400,000 dollars per year lost sale for water hauled down into the Southern
11
Humboldt County area by water truck that has been lost.
12
The Burl Tree owns 832 Westgate Dr. and ALL the land which defendants ruined, and which
13
now they must remediate. The Burl Tree also owns all the property on the site including damaged
14
inventory inside and out, and all land and property damaged here both inside and outside is a Burl
15 Tree business loss. The Burl Tree now operates at least 99% in interstate commerce, so therefore
16 defendants racketeering enterprise damaged a business operating in interstate commerce and hence
17 RICO is enforceable here under federal law.
18 When the Burl Tree purchased 832 Westgate Dr. in 1980 and developed it with over $700,000
19 of improvements, that was all business assets, land, landscaping, fixtures, tools and a huge
20 inventory, and today there are very few individual assets stored here. Additionally, the Burl Tree
purchases most of its inventory, fixtures and supplies from out of state, and over the last 30 years
21
probably no more than 7% of its purchases were within California. THEREFORE, the $12,000 per
22
year rent since 1998 which defendants owe, is to the Burl Tree, not Remington personally. The Burl
23
Tree always operated about 90-95 % in interstate commerce and since 1998 it has been 100%.
24
Gans is the primary violator here under 1962 (c) but the other co-conspirators, however also
25 committed predicate acts personally, and are consequently jointly responsible for all Remingtons
26 damages, according to a subjective formula Remington has estimated and proposed later in this
27 statement, subject to Court scrutiny obviously.
28 G. Conclusions: Gans is a hybrid of Don Corleone and Tom Hagan, the crooked lawyer,
Consigliore, in the Godfather film. With Allieds billion-dollar backing, Gans is literally as
8
powerful as the Godfather and has major enforcers muscle in Skillings and John Mathson, both
1
cold, heartless, bold and psychopathic.
2
Consequently, after eight years of extortion, vandalism, arson, Burglary, threats and severe
3
intimidation by Gans, John Mathson and Skillings we have reached this point.
4
Rather than just go-away, Remington is doing the opposite: Recording all this, increasing
5 surveillance, more aware of danger is in the dark shadows and other personal safety safeguards,
6 pushing a criminal investigation centered on Olsen, Skillings, Madison and Kish Paul initially and
7 investigating all involved in terms of RICO.
8 Nevertheless, Remingtons life is now threatened and in danger. That has always been the risk
9 and price of facing organized crime, with its unlimited power and resources, and it still is. If
4
10 Remington is killed here, start with Skillings and then lock-up Gans until he confesses. Gans is
still believed to have at least one Eureka judge in his pocket, as Corleone did, and obviously it is
11
personally stupid to oppose such power and corruption, however Remington is just too proud,
12
bullheaded, idealistic (and perhaps foolish) to just go away, and still believes there is a possibility
13
of justice in California, if one has the 10-20 years to achieve it. Remington also still has very high
14
idealistic aspirations for his vast gardens and Gothic ornamented estate here, and hopes to donate it
15 or otherwise cause it to be used as some sort of county or state park in the intermediate term. That
16 would not be possible in its contaminated and un-indemnified present state.
17
18 II. RICO Case Statement Standing Order Form
19 (alleging substantial and direct monetary damages caused to Remingtons property in business).
20 1. State which section of 18 USC 1962 that defendants alleged unlawful contact violates.
The alleged RICO act criminal conspiracy is in violation of 18 USC 1962 (c) & (d). The
21
enterprise made huge profits and reinvested most or all of them in other real estate development,
22
construction and office equipment, etc. However, said reinvestment probably did not directly
23
damage plaintiff nor are sufficient details presently known to present a viable 1962 (a) or (b)
24
claim, but we reserve the right to do so after a couple years of discovery. The causes of action in the
25
26 4
Skillings is the Luca Brassi (the Godfathers sensitive but psychopathic hit-man) of our story, Remington fears.
Skillings is a cold, ruthless, potential assassin-type. During and after his SOL cross- examination in 2016, where
27 Judge Reinholtsen refused to admit or allow the use of 2003 photos proving absolutely that Skillings was lying,
which both Gans and Remington well-knew, Skillings glared at Remington. Not just an ordinary stare, but as he left
28 the courtroom walking only 5 feet from Remington his eyes clearly and very unmistakably said: Keep this up
Remingtonand Ill kill you next time, and Remington doesnt intimidate that easily, unlike the rest of his warm
and sensitive family, which are now successfully extorted and intimidated, as per below.
9
complaint list section (d) as a separate violation, but based on conspiracies involving the (c)
1
violations.
2
2. List each defendant and state the alleged misconduct and basis of liability of each
3
defendant:
4
A. Russell Gans, Esq. (next 84 pages)
5
(1) Early Introduction, from 6 months ago and now of only general relevance, as noted
6
BELOW. Gans is the primary conspirator, organizer, ringleader and acting godfather of their
7
criminal enterprise of over 40 people, but law partners Brisso and Plotz provide daily substantial
8
support of at least several hours per day.
9
(2) The following 74-pages summarize some of Gans presently known DIRECT
10 involvements in all, at least, 18-types of federal predicate acts, which emphasize extortion and
11 were mostly carried-out in direct criminal collusion with John Mathson, (his Westgate gang) and
12 Kyle Skillings, who Both take orders from Gans, and John Mathson literally does nothing on his
13 own initiative without clearance from Godfather Gans, as he behaves like a ventriloquists
14 dummy. [SEE ALSO PAGES 532-553 of Remingtons RICO statement, below, for 20 more
15 pages of MOSTLY GANS unethical and quasi-illegal litigation activity.]
It is very likely that these lists will greatly expand in types of crimes and specific instances of
16
same as further work, research and recall occurs here, PLUS written and oral discovery during
17
2017-18, will greatly multiply the number of predicate acts within the 18 categories, so far
18
determined. That last prophetic statement written about six months ago has already been expanded
19
with respect to Gans to include his personal involvement in all of the so-four named predicate acts
20 listed at pages 4-5 of Remingtons RICO statement, in Volume II.
21 Further and very significantly, when the first RICO enterprise member cracks and decides to
22 tell the truth to save themselves, there is no doubt that additional specific types and individual
23 incidents of said above 18 categories of federal predicate acts will be discovered, proven and
24 encompassed in the FAC, in a year or so. Also, around that time Remington will automatically
25 update and probably condense the RICO statement somewhat, when time permits.
(3) After the short summary of some of the major categories of Gans initially discovered, 6-
26
months ago, federal predicate acts (which follows next), we will cover some of the major categories
27
specifically, with all required fraud SPECIFICITY, as follows: Extortion, bribery, mail fraud, wire
28

10
fraud, obstruction of justice, and the other five or six federal crimes described throughout, as
1
follows5:
2
1. Extortion, violating 18 USC 1951, 2014-16, as below;
3
2. Bribery, violating 18 USC 201, from 2012-16, Related To Randall, the file room, Costa,
4
Kishpaugh, Skillings, Esko, Ferriman, Gwinn, Remington, details below;
5 3. Mail fraud, 18 USC 1341, 2012-16. Extensive, involving Remington, the courts, Allied
6 insurance, the RAO-Kluck, Allstate forces, Randall, Jeff Nelson, Blue Rock, Etc.
7 4. Wire fraud, 18 USC 1343, 2012-16. Phone and internet involving the same people above in
8 furthering all the criminal acts described herein;
9 5. Obstruction of justice, 18 USC 1503, this allegation includes, without limitation:
10 Paying (or bribing) a state court file room employee to repetitively separate, unbind, scatter
and misplace Remingtons lengthy documents and lose them, or not timely deliver them to the court
11
for hearings. That still happens today about 20% of the time when Remington files State
12
documents, which is about 20 times in 100 major filings which average 250 pages each and were up
13
to 2000 pages; Gans also personally visited the dump site, based on 2016 surveillance videos, to
14
tamper with evidence (personally and to supervise his soldiers); Gans suborned perjury in at least
15 five (5) of his August 2016 trial witnesses and retaliated against Remingtons star witness
16 remediation expert Figas, Mike Foget, Remington and others; As contained in more than 1000
17 pages of federal and state filings, Gans filed multiple false declarations, plus fraudulent,
18 deceptive, mischaracterized false expert declarations, knowingly inaccurate and replete with
19 multiple gross misstatements (on every page) in numerous federal motion documents, from about
20 2010-2014, and many were repeated in his 2016 MILs. Generally speaking, the enterprise
defendants are almost entirely misleading and unethical in all of their written documents, and said
21
documents also misstate or conceal at least the majority of the material case facts and issues,
22
which would be required for an honest representation by defendants, if anyone were evaluating
23
them aside from Remington.
24
SEE Sections X-Y, around pages 82-88 below, for MORE Gans transgressions, ethical
25 violations and specific California statutes violated, some of his earliest perjuries, FRAUDS on
26 Remington and the state AND Federal Court (in CV 09 4547 NJV) which were precursors to
27
28 5
All of this section has obviously been totally superseded by the by the subsequent 550 or more pages that
were drafted over the next six months to more fully characterize Gan role as leader of this RICO
enterprise.
11
federal crimes, and are mostly but all less serious than the federal predicate acts outlined in the
1
next 70+ pages.
2
All the details of Gans individual state and federal crimes plus those directly carried out by
3
his soldiers under his direct supervision and CONTROL, are covered in detail in the following
4
sections.
5 6. 18. 42 USC 102, ARSON. Allegedly perpetuated by John Mathson in September 2008, as
6 discussed herein, based-on his known enmity and presence at the scene, easy access to the crime
7 area through his secret door, two witnesses and the other evidence cited. Mathson is a puppet
8 who ONLY acts under Gans orders, and here there was strong incentive to terminate Remington
9 and his defenses early-on, as said arson occurred in the last few days before a giant Special
10 Motion and litigation privilege defense by Remington requiring a month of full-time research.
Likely, there is nothing significantly better than starting a giant fire which almost burns your
11
adversaries OFFICES and PERSON TO DEATH, to obstruct a motion Opposition, which
12
defendants motion was also frivolous but did require a massive Remington Opposition under the
13
circumstances and unfamiliarity of the topic.
14
WORSE and more damaging than that fire overall was the 500+ hours thereafter wasted
15 because of the REAL FEAR of a repeat at any time, 24-7, 365/year, damaging Remington as
16 below, and because it has since required him to HAVE to record daily, on remote hard-drives and
17 Cruzer chips, for 8 years every 10-100 pages drafted in these cases, usually at 1-2 day intervals,
18 which amounted to THOUSANDS of onerous saves of up to 500 drafts of major documents, such
19 as THIS ONE, in to avoid 5-20 hours of hard thought, legal and word-processing work being lost in
20 the next arson attempt or success, likely while Remington is away from his offices.
That real, RATIONAL fear is just more EXTORTION, but is listed here separately for
21
emphasis and to incriminate Gans, Mathson or Skillings when it occurs NEXT.
22
7. OTHER Gans serious, actionable transgressions, generally, include, without limitation:
23
Major, severe witness tampering (on the key, crucial, most material issue of the SOL trial),
24
coaching, coercion and retaliating against Remingtons witnesses; the Obstruction of law-
25 enforcement in conducting a quasi-illegal MAJOR gambling business6, in the sense that all
26 6
As explained elsewhere, Gans alleged RICO racketeering enterprise exactly meets the definition of an
27 illegal gambling business, at 18 USC 1511 (b) (i-iii), in that: (I) It was a violation of the law of the state
and political subdivision in which it was conducted; (ii) it involved (s) five or more persons who conducted,
28 financed, managed, supervised, directed, or owned all or part of such business; and (iii) it has been, and
remains in substantially continuous operation for a period in excess of 30 days or has (had) a gross revenue of
$2000 in any single day. The RAO- Mathson original crimes easily met those criteria from 1998-2006, and
12
defendants roll the dice on whether Mathsons' dump would be discovered or remain concealed, or
1
not and also whether major civil or criminal charges would be filed or not; money laundering
2
subject to future discovery; buying and selling real estate with laundered money; the 2015-16
3
improper hauling, permitting and placarding of hazardous wastes; miscellaneous actionable
4
deprivations of Remingtons rights (See Section Y. about pages 83-86, for MANY more); and the
5 selling of controlled substances by the enterprise.
6 All of these above federal violations will be covered specifically and chronologically in turn
7 below, in considerable and painful detail, including time, place, circumstances and participants.
8
1. EXTORTION (FIRST) AND THEN A SUMMARY OF OTHER FEDERAL PREDICATE
9
ACTS BY GANS HIMSELF AND COMMITTED UNDER HIS DIRECT ORDERS.
10
A. Background: In 2007-9, there were early precursors to this RICO action, upsetting
11
Remington because they were overly aggressive, unethical advocacy, but apparently only
12
California ethical violations that no one in the California Superior Courts seemed especially
13
concerned with. That was LONG before any pattern or racketeering enterprise was noticeably
14
formed. THIS section originally drafted in fall 2016 was augmented in February 2017, as section X
15
and Y. below, as these more minor 50-70 serious ethical violations, FRAUDS on Remington and
16
the court, deceptions of jury and THREE judges in both state and federal court, seemed to become
17
more relevant to put this RICO suit in perspective, even if said above 50-70 violations of Gans
18
oaths, moral code and ethics might not be imprisonable predicate acts, still they are BAD and this
19
court should be aware of EVERYTHING going-on here, for years.
20
1) Beginning in 2008, Gans and Brisso of the Mitchell firm embezzled funds from their financier
21
Allied Insurance, grossly inflated costs to them and then to Remington when he was billed for
22
swindled costs already paid by Allied. In those 2008-9 special motion fee hearings the Mitchell firm
23
burglarized, over-billed and attempted to extort Remington by more than $9000, but failed in that
24
attorney white collar robbery of Remington, when Judge Miles believed Remington briefly and
25
long enough to follow his 20-30 pages of proofs which implicated Brisso and Gans; 2) Also in
26
September 2008, John Mathson is strongly suspected (and seen nearby) in the actual, serious arson
27
fire at Rs 5000 square foot residence under construction, while Remington was simultaneously
28
defending against defendants Special Motion and 40 organizational complaints, discussed
Gans enterprise has easily met them since then, and from 2012-2016.
13
1 elsewhere, but 3) in any case; summer 2011, 4) serious defendants experts declaration perjuries
2 and errors in all their expert FEDERAL and STATE reports related to encroaching volume, toxicity,
3 but not yet formalized as perjury at any trial; 5) John Mathsons vandalism pattern was established
4 in 2008, but was in its infancy, and easier to contain then, compared to organized, systematic
5 attacks in 2012 and ON to the present, facilitated by his two different secret doors described
6 herein; 6) also early threats, anger, extortions and attempts to break Remingtons spirit and that of
7 his experts occurred as early as 2008-11, but not as serious predicate acts then; 7) The Mathsons
8 poured, spread and otherwise allowed untreated feces, urea and associated diseased bacteria and
9 viruses to flow down onto Remingtons land from their unpermitted, but expensively BUILT
10 (anyway) illegal septic system since about 2005, again hardly a felonious federal crime, although a
11 very serious and potentially deadly health threat to Remington and the community, almost
12 KILLING Remington several times already.
13 AGAIN, see the 50-70 GANS prequels to and simultaneous corrupt, improper, illegal,
14 wrongful, ETC federal precursor predicate acts, at Section Y below, which Gans committed
15 between about late 2011-2017, all REPEATED in state and federal documents during the past 4
16 years, which although not necessarily arising to RICO acts, still set the tone, pattern and are ALL
17 BAD and consistent with the FEDERAL and state CRIMES alleged.
18 B. In 2012, Defendants RICO pattern of discrete federal predicate acts began, and
19 continued open-ended continuity, through today, in November 2016 (in approximate
20 chronological order):
21 1. Attempted Extortion by 100+ acts of Mathson-Skillings felony vandalism and burglary
22 over many years. [Recall that all of these proven criminal acts by Gans RICO soldiers, for
23 which we have evidentiary proofs, were carried out under Gans direct orders and with his
24 direct knowledge and supervision].
25 John Mathsons Burglaries of burl, iron, mill and agricultural machinery, tools, supplies
26 and equipment, PLUS his serial vandalisms of Remingtons mile long perimeter fences, nursery
27 plants, ALL Rs major gardens, miles of irrigation lines and dozen pumps, and Mathsons personal
28 leadership of his documented, tame and trained deer armies, VIOLATE 1951, the Hobbs Act.
Since Remington has not YET surrendered his encroached land or dropped his lawsuits, the
14
1 defendants crime of EXTORTION is not legally complete and prosecutable, however,
2 ATTEMPTED Extortion, under PC 518 with wobbler sentencing prescribed under CALCRIM 1830,
3 et seq, 1A, and PC 524, IS complete. Gans and Mathson have unlawfully ruined, destroyed and
4 VANDALIZED Remingtons property for years and have threatened to and actually CONTINUED
5 to do that vandalism throughout 2016. The damaging crimes continue and all future and daily threat
6 remains, implicitly until Remington renounces all lawful attempts to cleanup and recover his ruined
7 and encroached upon land, now HELD by Mathson and Gans.
8 We now understand in February 2017, that Gans, Mathson and all of the RICO conspirators
9 have violated numerous other California Penal Code sections which will be pursued to the full
10 extent of Remingtons energies if this federal RICO case stalls for some reason. Some of those
11 numerous penal code violations which were recently uncovered in about 15 minutes include
12 without limitation: PC 186-186.8; PC 518-19; PC 67-8; PC 92-93; and PC 137-8.
13 By November 2012, John Mathsons extortion pattern had increased in magnitude and
14 frequency to at least once a week and have continued at that level since then. See Remingtons
15 documentations by date, location and severity, from about 2008, and in detail from 2012 to present.
16 Recent 2016 video, from increased surveillance cameras, prove Mathson is letting deer, bear,
17 humans and other detrimental animals and forces into and through Remingtons fortress-like
18 security systems, and virtually impenetrable fences (without destructive vandalism) almost daily,
19 since becoming re-emboldened in August 2016, terrorizing Remingtons family, grandkids and
20 causing the extensive economic destruction to the numerous types of delicate Burl Tree property
21 present and the other HUGE damages cited, according to proofs.
22 As part of that coercive intimidation and worse, Remingtons parked pick-up truck has been
23 repeatedly vandalized and sabotaged in his driveway (as the Mathsons have called it ugly and part
24 of a junk yard) and also his basic transportation car has been tampered with in the public street in
25 front of the house;
26 THOSE documented and photographed criminal racketeering acts by Gans soldiers,
27 Mathson, Skillings and Kishpaugh especially are the enterprises primary extortion scheme to
28 DRIVE Remington from his land, harm that land and development, and destroy the Burl Trees

15
1 inventory, building, fixtures, gardens and all business development here, which is everything
2 located at 832 Westgate Drive, the property at issue here;
3 2. John Mathsons intimidation and extortion of expert Mike Foget, violating 18 USC 1951,
4 1503, 1512-13, occurring twice, in summer and winter 2012, during Fogets engineering visits
5 here in 2012. In 2012, John Mathson jumped-out from behind a redwood and yelled serious
6 intimidating threats, exhibited crazed, unpredictable anger, simulated silenced rifle shots with a
7 flash camera, threatened bodily harm and exhibited frightening irrationality;
8 3. Felony sabotage vandalism by Mathson causing Remington severe anxiety and fear, and
9 his wife and grandkids real palpable terror, fright and even some panic, in the four-year-old.
10 Remingtons main 8500 gallon irrigation Tank A was especially sabotaged by John Mathson,
11 with a heavy spear, on a known 2013 date in everyones records. Humboldt County sheriffs were
12 called for this felony mischief, investigation and interviewed both Mathsons, who lie well and
13 denied everything. Many details exist of this episode, where signs were posted and manipulated by
14 Mathson who enters Remingtons well-fenced yard at will through an elaborate secret door
15 Mathson built into his solid 8 fence in about 2008, PROVING his malicious, long-term intentions
16 SINCE that time. Tank A also happens to be only 6-feet from Mathsons secret door described
17 elsewhere which cause most of Suzanne Remingtons fright, as she thought shed seen a devil -like
18 ghost peering from within the fence, which is described below, Remington argued about initially
19 but now is proven that she was absolutely accurate.
20 John Mathsons numerous string of crimes against Remingtons family included: Over
21 100 major vandalisms of Remingtons perimeter fence and gardens by himself and his fellow
22 invaders; at least 10 equipment and major burl thefts are attributable to Mathson while the
23 fences were down; at least eight major, expensive Westgate Anderson Windows (double pane,
24 up to 2 x 6) were broken; at least one arson attempt on the structure is attributable to John
25 Mathson; and Gans, Mathson and Skillings all were involved in driving-out Figas with the
26 resulting lost iron sales and major damaging slides, fully described below, which are still not
27 stabilized even today, and still pose a serious threat to Remingtons entire natural highly
28 ornamented and decorated French Gothic stone million-dollar structure.

16
1 Those felony incidents violate 18 USC 1951 and also 1512, as an attempt to intimidate
2 star witness Bruce Remington and make him too fearful to leave his property or to testify against
3 the Mathsons or any of their criminal enterprise conspirators.
4 Obviously, Gans and his RICO enterprise members have many other objectives such as
5 terrorizing and removing Remingtons wife, Suzanne from having any involvement in these cases.
6 She would be his best witness, but has become too frightened, terrorized and refuses to testify or get
7 emotionally involved in any of these problems, because they are just too unpleasant for her, cause
8 her anxiety which disturbs her sleep and her psychological counseling practice, and because
9 Mathson and Gans reign of terror has just gone on too long with no end in sight, ever. In other
10 words, Gans extortion has fully worked on Suzanne already, and on his three (3) very young
11 grandkids, and on his tougher daughter to some extent, but not yet on Remington, who expects to
12 continue this defensive struggle on to the grave and/or beyond.
13 4. Malicious mischief violating 18 USC 1951, 1512, 1503 and 1512 (involving
14 PROMINENT expert and witness Bob Figas, and Remington7. In late 2012, John Mathson was
15 caught: Snooping around Remingtons entry gate, 4 hours after dark; leaving Remingtons yard
16 hurriedly; leaving Remingtons Burl Tree gate unlatched (and unsecured), as he studied Figas
17 loader to determine whether the key was in it and how to vandalize or BURN it, according to
18 proofs. Remington fortunately (and luckily) caught him in the act, before we had live security
19 cameras set-up, while Remington unexpectedly was going to get something from his car about 10
20 PM, see also 6. below;
21 5. Were going to KILL you! ( 1951, 1503 and 42 USC 1983 violations). In December
22 2012, John Mathson, who always circled Remingtons entire property perimeter, virtually every day
23 for 3-5 years, more than one mile of steep terrain by Mathsons route, mouthed the above just
24 barely audible statement, for the first time. Several other variations on that type of blatant extortion
25 occurred one or two other times subsequently at different locations and usually after some motion
26 victory by the enterprise. Mathsons work was then, and still is when Remington is out working,
27 to take many pictures, look for animals and their trails in terms of fence vulnerabilities, and to stare-
28 7
Remington herein alleges that Gans and his enterprise violated 18 USC 1512(a) (2) (A) (B) (I) & (ii)
DIRECTLY, blatantly and specifically with respect to Remington, Figas, and several others of his
witnesses indirectly.
17
1 down, harass, EXTORT, scare, coerce, make Remington as uncomfortable as possible and prevent
2 him from enjoying his work in his gardens, and in general threaten, and accomplish the above
3 mean-spirited objectives against Remington daily, if possible. Mathson knew expertly the local
4 deers feeding habits, schedules and also Remingtons work pattern, on-going projects and arrival
5 time, very precisely. He has studied both for many years, is certifiably crazy, a psychopath and
6 has been obsessed for many years with vandalizing Remingtons fences and property, in order to
7 make Remington miserable enough to give up the lawsuits and leave the entire community, as
8 described throughout this statement.
9 Every day, for years and continuing, Mathson would LOOK for Remington working, posture,
10 look confidant, attempt to intimidate and rudely (or bravely) stare down Remington in daylight,
11 as he circled DAILY. After several years, when the circling, staring and photographs did not really
12 work AT ALL, Gans and/or Joy Mathson must have suggested he up his game to SERIOUSLY
13 force the hated Remington to pay-attention to John Mathsons territorial strutting and ominous
14 usually silent glares and threats. On or about December 7-8, 2012, according to business records,
15 while Mathson was walking along Westgate by Remingtons gate while Remington was fixing it,
16 Mathson coldly and rudely stared at Remington, and without ever breaking stride or attracting any
17 attention to himself, he softly mouthed, so no neighbors friendly to Remington could hear:
18 Were gonna to kill you, motha fucker, or indistinct, ignorant, nasty words to that same
19 effect, from about 30 away.
20 John Mathson attacks and damages Remingtons front gate more than any other single area,
21 because it is so unlikely, well-patrolled to the point of complacency, somewhat porous, with
22 several different types of gaps and is therefore vulnerable. For example, in Mathsons two latest
23 acts of vandalism: On November 15, 20168 he removed interior fencing in the Cooksey-side 15
24 thick privet hedge and cleared a deer path, Remington discovered that evening and repaired. Early
25 8
That occurred on the day that Remington was writing this section, and subsequently at 3-5 day intervals
26 Remington discovered other major fence cuttings, animal invasions and the resulting damages which
Remington wrote into these documents every several days during the hundred+ or so days it took to write
27 this document. After a while though it got totally redundant and citing all the specific dates went on without
end, and at this point, now and February 2017, Remington just adds that new major destructions of Burl
28 Tree property occurred every few days during late 2016 and continued into 2017, no different than in 2012,
2013, 2014 and 2015, etc. Only the weather and the amount of tender young Rose petals and buds seem to
alter the frequency of Mathsons gangs incursions into, and destruction of Burl Tree property.
18
1 the morning of November 16th he again ATTACKED the gate at two different vulnerable points,
2 actually bending several metal support frames enough to allow deer to enter and also removed a
3 vertical bar blocking the latching and locking portion of gate which opens about 2 to allow human
4 entry. Remington caught and REPAIRED-WELL all 3 deer openings (or human) above and took
5 9 photos of all 3 for discussion and uses at a RICO TRIAL.
6 Remingtons wife, SUZANNE, hears the details of a lot of these stories, and thats why she
7 now is frightened to go over there because her anxiety is too unpleasant to allow her any pleasure
8 from a visit. Therefore, she never visits, except in the case of the following emergency when
9 Remington did not return home for about 12 hours. She has not been there in many years,
10 except once two years ago, when Remington was too ill to phone for help or leave there, in early
11 2015, and then Suzanne came over to see if Remington was still alive, and a few minutes later she
12 called an ambulance, worth to attendance hand-carried Remington out of there, in the dark.
13 The grandkids and Remingtons daughter do not hear any of these sordid details, but have
14 picked-up a few unpleasant vibes from all these scurrilous activities, real and valid dangers
15 (described below) and imagined fears.
16 Suzanne Remington has actually still not recovered either, from her last visit and unpleasant
17 and frightening encounter with John Mathson in about 2012, when while we were admiring,
18 smelling and picking several bouquets of roses (from among our 5000 bushes) on a bright sunny
19 day, suddenly she looked-up and saw a nasty, hostile, swarthy terrifying face lurking surprisingly
20 from in the middle of a solid eight-foot wooden fence. When she reacted with surprise and fear,
21 Remington discounted it and said it was impossible and she must have imagined it, etc. Suzanne
22 insisted that she had seen something, like a mans head sticking in through the fence, and some
23 impossible manner, but since Bruce Remington did not see it, he pooh-poohed and discounted it,
24 and assumed she had made it all up, which of course Suzanne knew that she had not.
25 It was only a few days later when Remington further considered and investigated the matter
26 and took a 6 foot aluminum ladder over to the fence and looked-over the back in the relevant area,
27 to see that lo and behold there was a clandestinely built-in secret door complete with discrete
28 hinges on the Mathsons yard side, which he could and did open to spy on us, and take photos like
a peeping Tom. Who wouldve guessed or suspected that?
19
1 Now a few years later, we understand that Mathson constantly watches us and especially
2 BRUCE Remington from there, and from many other specially designed and cleverly built duck
3 blinds and various bushes, both from his property and also on Remingtons property itself.
4 Mathson maintains and mans those surveillance subterfuge locations daily, and is continuously
5 ready with flash camera and presumably one or more firearms.
6 Remington understood instantly in 2012 when he saw how cleverly Mathson had built his
7 secret door into his solid wood fence with a considerable degree of craftsmanship and skill, what
8 the intention of that secret door was. The door only had one real purpose which was to enable
9 Mathson to readily and discreetly trespass onto Remingtons property every day, which he did and
10 still does. None of this is speculation however, because Remington set up several security cameras
11 in that area since 2014, and has numerous clear surveillance videos of Mathson slowly, discreetly
12 and very guiltily opening his secret door in order to trespass onto Remingtons land and do his
13 destructive activities described. Those videos have been saved for trial but they do portray a
14 peering, leering, peeping Tom (or here a peeping John), who looks very ruthless, swarthy,
15 unpleasant, nasty, desperate and crazed like a psychopathic criminal, as he frantically looks-around
16 to see if he is being watched directly by anyone, as the cameras were unexpected initially.
17 6. Major, damaging 1951 and 1512-13 successful extortion, blackmail, harassment,
18 coercion and intimidation of central R expert remediation contractor WITNESS Bob Figas, an
19 IMPORTANT early, specific series of predicate RICO acts, in this case.
20 Beginning in December 2012, and escalating in intensity, severity and effectiveness in January
21 to May, 2013, Skillings and Rich Olson directly, intentionally, actionably, and independently
22 (witnessed) intimidated, coerced and actually successfully extorted and blackmailed Bob Figas.
23 This series of at least 3 phone calls and possibly one visit will be discovered MUCH further as
24 Figas is afraid to freely discuss it, since the threats all STILL APPLY today and promised
25 immediate severe physical retaliations to Figas, his equipment, business (or on his shops and
26 buildings). THIS is a central and important RICO predicate act because it directly, provably and
27 dramatically DAMAGED the Burl Tree in MANY different ways, as explained above:
28 1) Remington and the business permanently lost scrap iron sales of approximately $20,000
in Portland, Oregon, for: significant tonnage of structural scrap iron, hydraulic sawmill power and
20
1 control units, large 3-phase motors, saw mill machinery (operating forklift, Silverado pick-up with
2 crane, mill feed and shop work tables, 26 x 10 band saw blades sales, and extensive 3-phase
3 wiring and electrical boxes, ETC. Figas was scheduled to load, remove and haul all that to Oregon,
4 not 3 days after he abruptly removed his 90,000# excavator and ran like a scared rabbit;
5 2) A substantial and critical portion of foundational land which supports the 50 tall, 8000-
6 10,000 square foot residential, working offices and storage facility for Remington and the Burl
7 Tree, collapsed and dropped 6 in a major slide only 2 months after Figas abruptly removed his
8 excavator (after hauling away Remingtons 80,000# loader). Although the exact dollar damages of
9 the slide are somewhat subjective, and may increase by 5 to 10 fold, at the moment the loss of the
10 land and devaluation of the gardens by dropping 6 feet with all its hundreds of plants and bushes
11 and trees, and the resulting hundred plus hours of reclamation work (so far), which it has cost over
12 the last several years, is valued presently at $15,000, only. Today, the entire massive structure is
13 threatened and jeopardized, because anymore slides in that area, will begin to involve actual dry
14 and solid land which is structurally needed to provide lateral support for the entire foundation and
15 massive weight described above.
16 The slide originally occurred BECAUSE Figas left 3 deep gashes in the road, which became
17 rivers in the first 3 inches of rain, which rushed into the 5 deep chasm and indentations left from
18 the loader removal job. In short, Figas failed to do the most basic or ANY obvious winterizing of
19 the site when he unexpectedly and abruptly left without regards for anything except his own safety.
20 HOW and exactly why that shocking set of circumstances occurred and how a mature, stable, very
21 nice and responsible 30-year friend of Remingtons could be frightened so much and so fast, still
22 remains to be probed IN DEPTH in this proceeding, under oath from ALL INVOLVED. Remington
23 maintains that Figas trepidation and dread was realistic and would legally exonerate him from
24 damages caused by his panicked departure. That panic was believed to be factually and reasonably
25 based, although eventually a decision for a trier of fact, and therefore Remington holds Gans and
26 defendants responsible for subsequent slides and structural damages at Westgate;
27 3) Additionally, Burl Tree property (as above has further deteriorated, water and electrical lines
28 were removed and damaged at that time in 2012) was damaged and inventory was damaged when
the detailed 2012 plans involving burl sorting, iron and machinery sorting and re-piling and
21
1 covering, etc. were NOT executed as scheduled. Thereafter, Figas claimed he was ok with all this
2 and would return in March, then May and now likely never because the KNOWN FEAR,
3 intimidation, extortion and coercion has continued and escalated. The precise blackmail has yet
4 to be investigated in Discovery, and whether Figas has the guts or motivation to stand-up to possible
5 Killers like Olson and Skillings is unknown and without criminal authority, or FBI involvement,
6 Figas may be unwilling to risk his life and million+ dollars of equipment backing an old pro per in
7 the face of such potentially VIOLENT forces, without SERIOUS PROTECTION;
8 4) Today, much of the inventory, iron and property above are inaccessible or depreciated in
9 value. The price of scrap iron and machinery is diminished by almost 50% from 2011-12 levels.
10 Significant profits in the $125,000 range have been lost permanently in this section alone, and the
11 slide above could cause $500,000 of damage alone. TODAY, said slide appears stabilized and has
12 been massively planted with tons of foliage and roots, but a major earthquake now could REALLY
13 destabilize the houses massive 150+ ton concrete foundations, which are all directly attributable to
14 Skillings removal of Figas in mid-project, in mid-winter, when no contingent mitigation measures
15 were possible;
16 5) Major volumes of redwood lace Burl sales were also lost to Lorn Sandberg located in Albany,
17 Oregon when Figas pulled out. Figas otherwise could have easily hauled $20-$30,000 of lace
18 redwood burl along with the iron, as Sandburgs on-line multiple species of burl business is just
19 minutes off I-5 on the route to Portland.
20 6) Finally, Burl Tree profits were directly impacted by the lost time of its operating executive,
21 CEO, chief production worker, builder, burl cutter, finisher, driver, operator, packer, administrator,
22 salesman and trouble shooting mechanic. The financial losses and case authority for attributing lost
23 profits to lost time involved in combating frivolous litigation will be presented in subsequent
24 forums, here and in state court.
25 In summary: RAO made believable, credible phoned and in-person threats to Figas that they
26 would destroy his excavator, his business, reveal Figas darkest secrets, and possibly worse if he did
27 any excavating at all on Remington's land in 2012. That was how it was characterized to Remington
28 in 2-12-13; HOWEVER, subsequent odd Figas behavior and multiple broken promises, most
recently concluded in 2015 with Figas suggestions and his URGING to find someone else (i.e.
22
1 Wayne Marsh and brother) to do Remingtons $200,000 of needed work proves this extortion goes
2 VERY deep and is SERIOUS. Inferentially, until the RAO threats are safely in prison, Figas
3 appears to have ORDERS (he is afraid to disobey) to stay off Rs land and not do any DIGGING
4 that would reveal skeletons and dark SECRETS, obviously. Otherwise why bother Figas and
5 Remington?
6 7. Remington herein asserts at least THREE (3) additional counts of specific, serious,
7 criminal, escalating ACTS of 2012-13 extortion, intimidating and misleading conduct,
8 obstructing an important expert and fact witness in state and federal proceedings, plus
9 retaliating against, threatening, bribing and/or improperly coercing a witness in a proceeding related
10 to the commission or possible commission of a federal offense. Specifically, in January-February
11 and inferentially at least once more in approximately May 2013, additional repeated extortion and
12 related blackmail, threats and intimidations caused Figas to break additional specific promises to
13 Remington. By May 2013 he had changed his position to refusing to return until Olson, Skillings,
14 Mathson and/or Gans permitted it. Initially, in early 2013, Figas just wanted to know about the
15 lawsuit, as THEY threatened him with being sued and having to potentially spend $100,000 on a
16 lawyer if Figas remained with Remington and dug one bucket of dirt or burl on Remingtons land.
17 Remington reassured him, he thought successfully, about that in January 2013, but RAO, Gans and
18 the ENTERPRISE worked on Figas further and again in spring 2013 while Remington was doing
19 other work. Inferentially, the enterprise blackmailed him with something in spring 2013, lost Figas
20 entirely in all likelihood, which well discover at some comprehensive, candid depositions.
21 8. More malicious mischief. Not every retaliation, extortion, intimidation and attempt to make it
22 easier for Remington to LEAVE than to stay, and fight was a felonious, Federal predicate act.
23 MOST were not, obviously, however the overall hostile, coercive pattern is clear and
24 EVERYTHING Gans ordered Mathson and Skillings to DO advanced their objectives:
25 A. Avoid all cleanup costs;
26 B. Avoid criminal and civil liability for their 1998 criminal activities;
27 C. Avoid prison for all, COVERING-UP any and ALL of this at all costs;
28 D. Occupy and KEEP Rs adjacent land RENT FREE and eventually get it ALL cheap;
E. Make exaggerated profits and exorbitant wages for all enterprise members; and
23
1 F. Crush Remington, slowly and painfully, no matter what monetary investment or violence that
2 requires. This part of the strategy also clearly involves terrorizing and crushing Remingtons
3 close family, especially his wife and granddaughters, all of home now appear to be poisoned and
4 unable to ever get any enjoyment from Remingtons large, beautiful and complex estate.
5 Specifically, in March 2014, Remingtons 8 tall, strong, well-secured fence, near Tank A,
6 along the property line, was broken-off a 4 diameter redwood tree by John Mathson 80 from
7 Westgate. Remington did not SEE him do it and did not have a bank of cameras along that border in
8 those days; however, ONLY John Mathson has access to that well-secured doubled-fenced-in area
9 behind his house and fenced yard protected by security cameras and yapping guard dogs, ALL night
10 long. Mathsons intention was to let bear in to spread serious amounts of garbage from several cans
11 put-out by neighbors. Predictably, and not accidentally, the first week the fence was removed from
12 its 4 diameter post, about 4 messy cans of very nasty organic and paper trash-worth of garbage
13 were eaten, and then scattered over 1000 square feet in two different adjacent areas of Remingtons
14 property. Whether wind blown or bear dont like to eat in a sloppy picnic area, the result was a big
15 mess for 200 and 30 of elevation in pretty impassable, rugged brush, amidst Remingtons gardens
16 and paths.
17 9. Gans extortion of Remington on May 26, 2016 with Morgan Randall, 18 USC 1951.
18 Gans intentional extortion of R over maliciously withholding the specific content of Randalls
19 imminent trial testimony in May 2016, was believed on that day to be only a few days before trial.
20 Remington was lawfully merely trying to get a basic 8 word summary of his surprise (previously
21 undisclosed) trial testimony and his immediate deposition; however Gans rudely and extortionately
22 refused, which was surprisingly backed-up by the too easy-going court, which would NEVER, ever
23 challenge his old law partner Gans on anything.
24 This episode is another example of unethical, rude litigatory behavior, and obstruction of
25 justice, but again to Remington crosses that line into racketeering in the RICO context. Randall
26 has not yet testified and Judge Reinholtsen surprisingly blocked his deposition. However, Gans has
27 inferred that he has been heavily coached and given another perjurious Gans script to memorize
28 and rehearse, and in the overall RICO context and Gans frivolous fraudulent (now settled
DR060669) lawsuit against Remington, Randalls secret, no-doubt false testimony is a further
24
1 transparent attempt by Gans to force Remington to give-up his affected million dollar property
2 free, in accordance with the enterprises objectives.
3 Defendants impacted, contaminated and ruined Burl Tree land worth more than $120,000 for
4 said impacted and appropriated land alone, plus they have defaulted on $12,000 per year rental,
5 and with back rent for 18 years now due and demanded totaling over $216,000. That sum is another
6 major rightfully due expenditure which the enterprises objective is to AVOID.
7 Because Remingtons entire very valuable development and estate is now unmarketable,
8 Remingtons and the Burl Trees total land and building depreciation damages alone are in the half
9 a million dollar range alone, PLUS back rent, which is why CLEAN-UP of defendants hazardous
10 wastes are required9.
11 Gans strongly inferred on the record in pre-trial Severance hearings, before settling his
12 frivolous offensive case for visual nuisance to appease and bribe the Mathsons, that Randall
13 would falsely swear that Remington contaminated his own property and creek and also implied
14 that Randall is the one who sold RAO and Mathson 6 perforated pipe in 1998 and recalls that sale
15 specifically amongst the hundreds of millions of dollars of Piersons sales since then. Since the 6
16 pipe in question has absolutely been proven to be solid, therefore what perforated pipe Piersons
17 may have sold to Mathson and RAO is meaningless. Obviously, they ALSO sold some solid 6 pipe
18 in that era, which they did not yet LOOK FOR probably, but if not Hensells Materials had it, and
19 sold it much CHEAPER than Piersons in 1998, in any case. Randalls deposition demand will be
20 reasserted imminently as will detailed Discovery demands about ALL related Piersons sales in
21 1998.
22 Gans fraud here is of the federal MAIL and wire (phone) variety because all of his
23 fraudulent, illicit cover-up requests, ordering him to duck Remington and not talk, in late May,
24 and much of Gans coached false Randall testimony regarding opposition to Remingtons
25 9
Clean-up is reasonable under Starrh v. Starrh, Mangini I-III, etc. because Remington has many
long-expressed special reasons for absolutely implementing a cleanup, when defendants
26 provide the funding, plus an expenditure of $160-200,000 for soils AND water remediation will
27 restore the overall fancy estate, residence, gardens and county park back to its pristine value of
about $750,000, as is. Almost completed, when the gardens and structure and driveways are
28 completed and finished up to the large French gothic, cathedral ornamented structure itself, for
about a final $100,000, the overall project could be sold for SEVERAL million dollars, i.e.
potentially $3-6 million.
25
1 severance motion in March-May 2016, was mailed, discussed over the phone and was ALL
2 intentionally false. Other than the enterprises CHIEF objective of crushing Remington without
3 costs or adverse ramifications, another major objective (above) was to make money for all and the
4 Mathsons have not made anything previously and their pay-days have been SLOW in coming.
5 Hence, Gans creatively saw an opportunity for an easy Mathson payday, at someone ELSES
6 expense besides Allied. Thus the extortive settlement from Farmers was a WIN-WIN situation for
7 the enterprise and against Remington and his backers and succeeded in getting RID of
8 Remingtons powerful allies, Farmers and Roberts.
9 EXTORTING more money from Remingtons Farmers insurer was brilliant of Gans because
10 Farmers admitted they badly wanted OUT of this Remington defense (that they never were fully
11 on-board with) for simple cost reduction purposes and expediencies. Thus, Farmers, Gans, Allied
12 and the Mathsons all WON in that bribed settlement. Only Remington lost visibly, but also saved
13 more than $20,000 of defense costs against Gans frivolous suit and potentially much MORE if
14 Gans could have deceived a run-away jury with more perjured testimony as he did at the SOL trial.
15 10. Gans February 10, 2016 intimidating, extortive phone call, 1951, Hobbs Act violation.
16 Remington called Gans to request that the depositions of Dr. McEdwards and Ms. Hoyos be set
17 for 4 hours later in the day to accommodate our schedules and conveniences, and Gans refused in a
18 reasonably pleasant manner at first, because he wanted to evaluate where Remingtons mind and
19 confidence were at. Next he went through a couple minute speech on how nice it would be to end
20 these cases, with Remington dropping his abusive charges against the poor, nice Mathsons, who
21 just want their life to go back the way it was, etc. Remington was not BUYING ANY of that after
22 Gans specifically rudely, callously and flatly refused to consider Remingtons reasonably based
23 deposition hour rescheduling requests, to accommodate Remingtons serious, related health issues,
24 at that time.
25 Next, being the smart negotiator and good deceitful actor and LIAR that he is, Gans
26 conspicuously reversed course and tried a HARDER line (to see if that might stick), but only
27 after seeing that the nice-guy, beaten-down, poor, tortured, sympathetic Mathsons approach was
28 failing.

26
1 Therefore, next, Gans tried his threatening approach. He angrily, improperly, (irritatingly to
2 Remington), unprofessionally (and criminally, it now appears), threatened Remington with total
3 defeat, and declared: Well destroy you, if you keep this up.... (and continue on the present
4 litigatory path).
5 Initially, Remington was primarily shaken and angered by Gans refusal to alter the deposition
6 times, set 5 hours before Remington normally even gets up and starts breakfast, and THAT was the
7 only purpose of Remingtons call, however Gans took that rare opportunity to negotiate and SEND
8 Remington a message. Remington was also a bit fearful of Gans abrupt ANGER, although not
9 really relying on his threats then, although basically just being angered and somewhat awed and
10 intimidated by them. A year later, Remington now understands exactly where Gans was coming
11 from and that he does have an ominous, powerful, motivated enterprise of more than 40 members,
12 not all named yet in this RICO action, and they have the overwhelming CONFIDENCE that
13 unlimited financial power brings.
14 Also, in that conversation, Gans next improperly demanded that Remington pay the
15 $12,000 debt owed to the enterprise; and thus, after the nice guy approach apparently failed,
16 Gans then attempted the racketeering enforcer approach and shake-down threats of: Pay us the
17 money you owe us now, OR ELSE. Similar demands have been made in writing about once a
18 year. Remingtons RESPONSE to that new extortion was: I have been paying, especially a few
19 years ago, but stopped when Remingtons bank balance was getting fouled-up by Gans NOT
20 CASHING any of the checks totaling about $1000. Remington keeps his money INVESTED and
21 NOT in a checking account so the fear we had was that Gans would hold a couple thousand dollars
22 of uncashed checks and then put them all in unexpectedly to cause a banking crises and attempt to
23 make Remington look bad to the courts, etc. why defendants had not even cashed the checks
24 Remington HAS sent to date. We discussed all that and thereafter Gans shut-up about the debt at
25 that point without threatening to put out a contract on Remington for non-payment of a mob, or
26 racketeering enterprise, debt.
27 Gans also further intimidated and seriously threatened Remington (as he did again 4
28 months later) with the DIRECT BELIEVABLE THREAT and specter of Allieds suing
Remington for ALL their costs and attorney fees for ten (10+) years, plus punitive and/or additional
27
1 damages for malicious prosecutions, and intentionally inflicting emotional damages on the poor
2 Mathsons, ETC.
3 11. Gans MAIN 18 USC 1951 extortion threat against Remington in mid-June 2016, in his
4 personally solicited main corridor meeting with Remington, during our mid-morning break on a
5 determinable June 2016 pre-trial hearing day.
6 This interaction was preceded by two relevant hearing occurrences and contexts. First,
7 Remingtons voice had just broken with emotion a few minutes earlier, when he was explaining to
8 the Court how hard it was emotionally to oppose his former good friends the Mathsons in these
9 proceedings, and the kinds of sensitive feelings and fears we had shared for years in the mid-
10 2000s. Essentially, Remington had just been thinking about how: When John Mathson went bad he
11 essentially ruined Remingtons life as it had existed happily previously, first with his massive
12 trespasses and land contaminations, fraud, and concealment and later with the feigned (we now
13 learn) friendship for several years, and then the eight (8+) years of criminal behavior sustained
14 from Gans planning, extensive legal cover and the essentially unlimited funds from Allied
15 insurance. As a result of all of that, Remingtons life has been made a living hell since then; and
16 second, the other immediately prior context was further discussion and reasons by Remington of
17 WHY Remington believed that defendants will NOT TRY THIS CASE, because they dont have
18 any experts left who are credible, or who are willing to be HUMILIATED now over their ERRORS,
19 or who will just LIE for Gans and swear to anything he writes for them. Remington had just
20 discussed all that in the department date oral hearing, and assumed that Ferriman and Gwinn were
21 fully discredited, knew it, were humiliated by it and were now apparently unwilling to follow Gans
22 racketeering lies, as discussed herein, in any case.
23 Less than a minute later, after Remington came out of the mens room, Gans signaled to
24 Remington to come over for a chat. For some reason Remington thought that Gans was going to
25 give-up then and there because he had no experts and hence NO defense in the contamination case.
26 However, Remington was exactly WRONG as usual regarding Gans intentions or possible
27 honorable or logical intentions or moves.
28

28
1 Remington was kind of surprised at the HARD LINE Gans then took, the opposite of what was
2 expected, but perhaps understandable if Gans really does not have any environmental experts for
3 the DR080678 trial, and only has the young, green Hillyard in reserve for FUTURE other trials.
4 When Remington came over, Gans kind of went for the kill shot and attempted to make
5 Remington An offer that he couldnt refuse. His intent being clearly to intimidate and cause fear
6 in Remington such that he would give up this case.
7 Gans said, words to the effect: You know, you could easily end all of this.Youd better
8 get out now, because we ARE going to try this and WIN. THEY ARE MAD.... Very mad and
9 they will continue this thing with the Mathsons until they WIN eventually after appeals (or
10 whatever) and then sue you for malicious prosecution and THEIR COSTS. They want their
11 costsIm only doing my job here, so dont blame ME for this. if you just drop this whole
12 thing, all these problems well go away, (No more early-morning trials, 3 hours of hearings
13 every day, vandalism, costs, anxiety, well forget the $12,000 you owe us, And its over, etc.)
14 They intend to get their costs and attorney fees, which are quite HIGH, no matter what it
15 takes...This entire 5 minute conversation takes 3-4 pages to fully recall and write-out fully. But, it
16 IS written out and will be covered fully at the next depositions, i.e. of Gans next, here.
17 The implications of those remarks were: you (Remington) get to keep all our contamination,
18 absorb your (Remingtons) $400,000+of remediation costs, expert and litigation costs, and other
19 damages, but all criminal acts would then stop. Gans seem to acknowledge that they were like a
20 criminal Humboldt mafia extortion racket, wherein he made the implied threats that They would
21 agree not to attack Remingtons business themselves any further, if they were able to meet all of
22 their objectives, and in essence Remington agreed to pay for all their protection services, which
23 clearly were and still ARE under Gans direct control.
24 Remington believes it is Hobbs Act 1951 prohibited extortion, but Gans predicatively will
25 cover-up with a purported opposite opinion, so the exact words, intonations, meanings and the
26 DETAILS and prior context must be understood.
27 12. EXACTION. Not a prescribed federal predicate act, under 1961 but not legal either.
28 Exaction means taking something by force such as during a theft or burglary. It is taking what is not
due, when nothing is legally due, as in a burglary, plus inflicting deliberate pain, suffering and fear
29
1 so that here Remington would give up. During these conversations Remington appeared to have
2 somewhere between $400,000 and a million dollars of potential claims, so what Gans was offering
3 in essence was if Remington paid $500k to him, or forgave that $500,000 which potentially
4 Remington could achieve over another 5-10 years of litigation, then defendants enterprise would
5 stop their fright and reign of terror that they had been escalating over the previous eight years,
6 CRIMINALLY in the last 4.
7 By extortion and exaction, Gans and his enterprise defendants have successfully instilled
8 dread fear and trepidation and Remington; actual serious fright, terror and very unpleasant anxieties
9 in Remingtons wife Suzanne (such that she never visits because it is too fearful and makes her
10 uneasy); however the worst effects of defendants 24-7 semi- reign of terror are on Remingtons
11 young granddaughters, aged 2-7. Beginning in August 2015 and occurring again at their next visit
12 in August 2016, the enterprise defendants succeeded in generating real fright and actual panic in all
13 of those children, by introducing real dangers here as well as many imaginary fears. Actual mother
14 bears with 2-4 cubs now thunder around among the rose gardens unexpectedly, menacingly and
15 potentially very dangerously. Also deer of all size are now always present when the children arrive,
16 some of which are huge and have menacing horns and if startled or cornered at all they charge away
17 unpredictably, in a panic and in low light, such as twilight, they run almost blindly away in
18 unexpected directions, and in 2016 one ran within one foot of straight-over Remington, at about 30
19 mph, as though it just had not seen Remington at all, and presumably wouldnt ever see a kid, only
20 2-3 feet from the ground.
21 13. Further, 18 USC 1951 extortion and thinly veiled THREATS: ...maybe hell die next
22 time....
23 The enterprises little joke walking home from the trial one day in the first week of August
24 2016. Remington packed-up very fast one day and caught-up to the Gans/Plotz/Mathson trial trio
25 about noon at the 5th Street crosswalk traffic light. Before they realized Remington was nearby and
26 gaining-on them, and crossing the street 8 away from them BEFORE the light went green,
27 Remington overheard the end of the following jokes:
28 Gans had said: ...maybe hell die next time..., or we can try something else..., with
laughter from Plotz at least.
30
1 Discovery will probe that entire conversation and little inside joke but Remington inferred
2 that it may have referred to the series of illnesses caused by the contamination from 2013-15, or
3 possibly the lethal arrows that Mathson frequently shoots over randomly into Remingtons gardens,
4 BUT clearly killing Remington by whatever means it takes is their preferred option.
5 In any case, now fearing for his personal safety, in November 2016 Remington invested in a
6 new batch of unbranded surveillance cameras, direct from China for about 70% off plus a
7 dozen 32 gb chips and (the new HDSC) card adapters for at least 80% off the prior prices of $10-14
8 each just last year.
9 14. John Mathsons 1951, vandalistic torturing, bullying, and protection racket extortion
10 continues through todays date, 11-20-16, literally. John Mathson is a typical shy, meek,
11 uncreative, non-initiative taking family soldier and is unlikely to commit additional criminal acts
12 without Gans orders and privilege protections. Gans is now keeping the extreme criminal
13 pressure on Remington, which continues in October and now November 2016, with an elaborate
14 series of holes in Remingtons South fence discovered about October 29, 2016. Then two additional
15 holes were discovered around November 11, and 15th, and repaired the same day. Prior to 10-29-16,
16 Mathson crawled through dense brush and a very solid established 30 tall privet hedge to remove
17 some non-climb fencing and a 50# burl slab blocking the passable channel between two mature
18 privet hedge trees, planted only 20 apart. That is enough for deer, bear and Mathson to squeeze
19 through, which they all DID. But NONE of these examples is ever the LAST criminal act (written
20 10-30-16).
21 Two weeks later when going over this draft, there was a new gigantic hole cut in Rs 25 tall
22 hedges and fence on November 11, 2016, which R randomly discovered after collecting
23 surveillance cameras, from the Mathson side. At dusk, as Remington removed a camera from a tree
24 near the Mathsons line he looked up to see a giant deer slowly ducking through a gapping hole into
25 Remingtons gardens. Since two cameras (with their full 32 GB videos, about 500 30-60 seconds
26 long) were missing, and presumed stolen by Mathson, Remington had missed that fence hole in
27 the twilight, and he walked right by, 15 away from it10.
28 10
. Although overly detailed no doubt, all this will be helpful to Remington and future principles in
these cases to understand these crimes exactly. John Mathson is wily, wary, observant and clever
like a street house burglar. He has noticed and Remington has explained his complex security
31
1 Remingtons gardens are still in full flower, leaf and rose bloom, even today in late
2 November, and until about January 1, thus considerable damage can and will be done by that one
3 deer in a few days.
4 15. As described above, Mathson has now taken to stealing Remingtons surveillance cameras
5 and their 32 GB chips, as he and Miller Farms were all over his yard from August 12th-18th, and
6 then into September- October, which is the period when one $100 camera is missing entirely,
7 including CHIP. That camera probably had recorded videos of multiple FELONIES and another
8 camera was found laying on the ground, far from where it had been hung on a TREE, with its chip
9 REMOVED, also. Inferentially again, presumably it had captured significant Mathson crimes of
10 vandalism so the evidence was removed and SPOILED. Well ask, but dont expect to see either
11 missing 32 GB chip again, with hundreds of hours of surveillance video on each. Remington just
12 ordered more cameras and chips direct from China, as prices are down drastically there, as above.
13 NOT a federal racketeering act maybe, but what you WOULD EXPECT from a mafia soldier, while
14 waiting for orders for something bigger. Everything Mathson does concerning Remington is
15 criminal on some level or another.
16 16. 2016 Violations by John Mathson of 49 USC 5101, et seq and 15 USC 2607, 2614,
17 2615 and 2642. In addition to the evidence spoliation, John Mathson has violated asbestos and
18 hazardous materials laws further here by: 1) Removing asbestos pipes and Chrysotile excavated
19 evidence from Remingtons land during 2016, caught on surveillance video; 2) then either secretly
20 storing it on his land illegally, behind two locked gates, or 3) putting it in his household garbage can
21 for routine pick-up, or hauling it on his own utility trailer. WHICHEVER procedure he followed, as
22 will be investigated during future Discovery investigations, it was unlawful, on multiple levels;
23 17. Ever since 2008, Gans and Mathson have violated and reduced Remingtons inalienable
24 due process rights (42 USC 1983) and damaged the Burl Trees value and ability to
25 function as a business by complaining to and causing the continuous frivolous harassment from
26 40+ governmental regulators, without one complaint ever proving valid, fruitful and non-frivolous
27 in basic substance. Other than burning several cardboard boxes in 2008 (a month ahead of the
28
network along the Mathson border, so Mathson went back to the opposite (Cooksey side 750
away) southern fences where there is plenty of hiding brush and no cameras, yet.
32
1 planned schedule), no Mathson complaint has ever led to any actual valid actions, by Remington or
2 any authorities, after an initial investigation and waste of all-involveds time and anxiety.
3 When a one-man manufacturing, research and sales business has to spend FULL-TIME,
4 every day interviewing investigators and escorting them around Remingtons large property, little or
5 NO FRUITFUL WORK gets done on those days, which here, eventually totaled many hundreds of
6 days.
7 Remingtons business working time has always (since 1970) been worth at least $1000 per
8 day and at times a million+ dollars a day, on the 8 or 9 days when he procured gigantic, lucrative
9 burl contracts, in an average of several hours of time each, with said contracts worth an average of
10 several MILLION dollars each, again, according to easy, detailed trial or deposition proofs.
11 Here, Defendants deprived the Burl Tree of its sole source of survival, Remingtons liberty
12 and his high level burl cutting and finishing, burl logging and related new product developmental
13 WORK, for months at a time, breaking all continuity with customers and sales, and losing millions
14 of dollars ultimately, JUST defending against Mathsons and Gans frivolous, now settled, as
15 above, 2008 lawsuit.
16 18. Gans 18 USC 1951, Hobbs Act violating extortion racket, defined. Gans has established an
17 extortive racketeering enterprise intended to destroy Remington and the Burl Tree and to
18 appropriate his land, while THEY all make lots of corrupt money, just as with any typical type of
19 organized crime family or organization. Here, Gans extortion racket has been trying to provide
20 Remington with protection from John Mathsons, et al, CRIMES against Remingtons land,
21 business and all property at that location.
22 Gans and his soldiers have clearly defined the threat for years, and made it much easier for
23 Remington to settle or totally give-up, however Remington never takes the easy way out, and is
24 a hard, serious fighter and worker11. Gans clearly defined extortion racket faces Remington and
25 is held over his head, daily, wherein:
26
11
Remington has worked hard and often alone since age 8, when he had an enormous paper route, several miles long,
27 delivered after dark in several months, with about 110 papers/day, with very heavy 200+ page papers 3-4 times per
week, the Washington Star, where Sunday papers weighed several pounds EACH (3-400 pages), and had to be
28 delivered in ice, snow, cold, windblown rain by thin-tired schwinn bicycle, with baskets on front and back, for years.

33
1 (1) Defendants have established an 8-year reign of terror from the above-described vandalism,
2 burglary, daily FEAR of same, and from Gans believably executed mayhem. The BASIC POINT
3 HERE IS: Gans has repeatedly, in 2016, made it crystal clear that HE controls the lawless
4 mayhem, destruction, vandalism and thefts of Burl Tree property and HE can STOP IT,
5 anytime.
6 Mathson takes absolute orders from Gans, and whether Skillings does or not, or is FULLY
7 controllable by Gans, today, is not yet known or proven;
8 (2) Gans will gladly provide Remington protection and STOP Mathson, and his other soldiers,
9 IF Remington will give them Remingtons and the Burl Trees valuable estate, land, inventory and
10 business, that they seriously, permanently (at least that was their 1998 plan) trespassed and
11 encroached on.
12 The Burl Trees ruined, encroached-upon land itself is now worth at least $120,000+, however
13 the more serious problem is the $300,000+ overall diminishment in estate and land value, the
14 $200,000+ BACK-RENT due, plus the related additional costs, personal injuries and general
15 damages, listed herein, related to the trespass and contamination successive actions lawsuits.
16 (3) The Burl Tree property has an annual water flow down Remington Creek of about
17 75,000,000 gallons of water per year, over the last several years, now lost due to contamination and
18 inability to meet ecoli and cleanliness standards. That gallonage at $6/1000 gallons is worth
19 $450,000, with about $50,000 pumping, storage and overhead charges at the most. As this
20 document is written Remington Creek is flooding and appears to have another $100-$200,000 more
21 water this year than last year.
22 Remington could truck that water to Southern Humboldt or sell it locally, for little additional
23 costs as independent contractor water trucking charges are passed to the buyers. THIS IS A
24 MAJOR ADDITIONAL BURL TREE DAMAGE, $400,000 PER YEAR!
25 (4) Gans extortion demands also have OTHER contingencies, codicils, terms and unacceptable
26 provisions, including that: A) Remington DROP his demands for back rents; B) Drop all his present
27 and future lawsuits; and, C) Drop his legitimate and mandatory DEMANDS for full insurance
28 indemnity against future cleanup orders from the down stream land owners, The County, State,
Water Board, National Park Service or EPA.
34
1 (5) In exchange for that, Gans says and infers THEY will also drop their future threatened
2 malicious prosecution suits, costs, expenses and attorney fee demands, which are NOT a BIG fear,
3 candidly.
4 Not much of a deal for Remington, and therefore unacceptable. Hence, we are here.
5 Gans total possible future demands and most optimistic returns in his best case scenario is
6 possibly $50-60,000 dropped in exchange for Remingtons obvious slam-dunk measurable,
7 visible ACTUAL contamination on the ground, plainly visible, and his resultant just due damages
8 of a minimum of $300-500,000 to as much as $3-4,000,000, if a jury ever actually considers and
9 accepts Remingtons view of these cases, or TREBLE damages are applied to some of them under
10 RICO.
11 Remington alleges Gans, RAO and defendants violated 18 USC 1511, in risking prison for
12 years with a gambling operation, meeting all definitions in that law. They buried hazardous
13 treasure in the beginning gambling that no one would discover it and now they ALL gamble that
14 Remington will not be able to execute its removal, even after its discovery, which is what these
15 cases are now about.
16 So far, RAO, Gans, Allied and Mathson are up about a million dollars or more on their
17 gamble, as though this were an Indian casino. However, ALLIED and all of them now continue to
18 roll the dice and play the poker hands or slot machines WITH that million dollars to attempt to
19 double it or maybe LOSE IT ALL. Well see. Maybe other alternatives will emerge in this Court if
20 these cases are accepted here.
21 (6) SIMPLY SUMMARIZED: DEFENDANTS EXTORTION RACKET FEARFULLY
22 THREATENS REMINGTON WITH THE QUID PRO QUO: You drop your lawsuits, rent, back
23 rent and cash remediation demands and WE WILL STOP OUR CONTINUOUS ALMOST DAILY
24 COSTLY, ANXIETY CAUSING criminal acts of vandalism (costing Remington well-over
25 $100,000 alone, to date); and also drop our cost, fee, punitive damages and malicious prosecution
26 demands. Generally, WE get all Remingtons land North of the creek FREE, and you take nothing,
27 and leave the area. OTHERWISE, there will be hell to pay and theres no telling what Mathson,
28 Randall, Kishpaugh and Skillings may do if unleashed from Gans civilized, corrupt control.
Pursuant to Mendoza v. Zirkle, 301 F 3d 1163 (9th Cir 2002), as quoted in Diaz, 420 F 3d 897, at
35
1 4, The 9th Circuit recognized a new business interest property loss relevant HERE: the legal
2 entitlement to business relations unhampered by schemes prohibited by the RICO predicate
3 statutes, (at 5).
4 #2. Basis of Gans liability continued from page 6, E
5 Bribery by Gans: 18 USC 201, 2012 -16. After further discovery Remington will further
6 definitively prove the following well-documented material acts of criminal bribery:
7 A. Randall Morgan in 2016 for the first time was named as a witness to testify falsely that
8 Remington contaminated his own property and also impossibly caused all pollution on Mathsons
9 land as well, which is 300 feet away, down the mountain, under a raging creek and then 100 feet
10 back up the next mountain, all of which imaginary facts are not scientifically possible.
11 Nevertheless, Gans paid Randall double or triple his normal salary, and on top of his salary
12 he agreed to be coached into participating as a disingenuous defense witness in the state
13 environmental contamination trial.
14 B. The file ROM saboteur/mole/criminal under Gans control, as alleged below is someone
15 that is being paid to get Remingtons case thrown out of court for lack of or improper
16 prosecution.
17 Someone is removing Remingtons motions, Oppositions and required filings from the proper
18 procedural channels at unexpected and crucial times every month or two and over the course of
19 many years. Specific instances are cited below and Remington has been complaining about it to the
20 court for years.
21 The penalty for that felony by Gans and someone (or two) unknown employees is very
22 severe, and at least 10 years in prison is anticipated, if apprehended. Hence, someone is either
23 related to the Mathsons by blood or being highly paid for their illicit work, which is at least 10
24 major very material document sabotages, any of which alone could have resulted in the dismissal of
25 Remingtons case had he not discovered the crimes and corrected these very material sabotages on
26 several occasions.
27 C. Bribery of Costa, Kishpaugh and Skillings. They were all heavily-coached for hours and have
28 little or no income, so being paid $100 or more per hour by Gans for practicing major perjury at the

36
1 trial in August 2016 amounts To bribery. By the time of the federal trial, we will be prepared, well-
2 equipped with prior sworn statements, cross-examination by omission techniques and be ready.
3 D. Esko and presumably Martel and Larry Lancaster were bribed in some manner with
4 money, or other considerations to greatly cross the line ethically in clearing the Mathsons of
5 any in all criminal and potential civil charges in an unsolicited manner, without any opposition or
6 input from our experts. False, unreliable tests and data were used and perjured testimony paid for
7 by Gans to Ferriman, Gwinn and Blue Rock Environmental were all used whereas our expert John
8 Aveggio was rebuffed.
9 E. Ferriman and Gwinn have been bribed all along as above on all material key scientific issues.
10 They have been paid $30-40,000, or more while doing very little, and what they have done has been
11 thoroughly discredited to the extent that Gans had to hire a third and fourth expert Schwartz plus
12 unidentified new tester (Hillyard) in early 2016 to try and cover for Blue Rocks errors.
13 F. Attempts to bribe Remington. By phone on February 2016 Gans tried to bribe and/or
14 coax or beg Remington to drop these cases for some nominal amount of money like $40,000,
15 because purportedly the Mathsons were so "distressed, overall or some useless, nonsensical
16 similar argument. Again, in June 2016 Gans tried extortion and/or related bribery, using fear,
17 as outlined above, and the promise to stop beating up on Remington daily. Gans also
18 promised not to come after Remington for costs and malicious prosecution and punitive
19 damages, etc.
20 #3. Mail fraud by Gans, 18 USC 1341, and Wire fraud 18 USC 1343. Remington could cite
21 30-50 instances of obvious, possible or perceived mail fraud between 2012-2016, and more
22 than 150 and the five years before that.
23 Federal Rule eight (8) prevents Remington from going into great detail at this juncture, so he
24 will cite only a few examples here, and elsewhere. Due to the large number of photographic charts
25 and exhibits submitted herein, Remington elects not to attach another 50 pages of letters, emails,
26 motions and phone notes in this document, but will do so in his opposition to defendants dismissal
27 motion, as required, and if disputed. A few recent examples:
28 A. Gans frivolous collateral estoppel (CE) Summary Judgment (SJ) Memorandum of Points
and Authorities on December 2014 to Remington and the Court, where he fraudulently
37
1 plagiarized the federal judges orders, and put in his own self-serving false and materially
2 fraudulent words, and then put false quotation marks around the false statements. Finally, Gans and
3 Plotz both repeated those false quotes repeatedly, where essentially they said black is white, and
4 repeated that ad nauseum in at least 12 places and in two sets of motion documents. In essence,
5 Gans falsely stated that the federal judge had found that Remington had not proven that Mathson
6 had contaminated Remingtons property, when all the judge really had found was that no evidence
7 had been cited that Mathsons property was contaminated, saying nothing about Remingtons
8 property at all.
9 B. On August 23rd, 2016 at 8:41AM, to Remington. Gans sent an email thread, continuing his
10 intimidations, legal threats and extortion demands from two months earlier and continuing:
11 do not trespass on Mathsons property. Moreover do not cause any form of subsidence or
12 damages. (If you do) therell be consequences of any such actions on your part, i.e. from
13 us, serious, swift and severe, as previously outlined and THREATENED in many documents
14 and conversations, for YEARS.
15 C. August four, 2015 email at 8:17 A.M. from Plotz. Here, he acknowledged sending Remington
16 an unintelligible 2015 SJ Separate Statement Opposition declaration that was missing many pages,
17 and when an error by Remington also got involved, Plotz refused to properly negotiate and remedy
18 the two errors and elected to try and prejudice the pro per plaintiff in the eyes of the court and an
19 unethical manner.
20 D. On July 16, 2015, the above litigation disputes and wire frauds, errors and communications
21 were received by Remington in Corvallis, Oregon while Remington was administering an estate
22 probate.
23 This example is proof of an interstate wire fraud (to Oregon), and any payments made by
24 Allied and/or communications from them concerning any of this to their home office in Iowa
25 necessarily also involves interstate commerce, wire, mail and/or interstate money laundering
26 transfers.
27 E. While Remington was sick and near death, Plotz on February 26, 2015 pushed the knife in
28 deeper by refusing to make simple stipulations about a continuance and oral arguments involving

38
1 defendants above-cited frivolous 2014 CE SJ motion, which was transferred from Judge Miles
2 Court To Judge Reinholtsens court.
3 Eventually, Remington went arduously up many stairs and into the courtroom with a walker,
4 making his needed oral arguments under great duress.
5 F. October 6, 2015 email, Gans to Remington. This was another example of Gans bad-faith
6 intimidation and attempt to lock-in Remington sole expert witness Mike Foget, after Foget had
7 already been officially de-designated by Remington, because his employer SHN had unilaterally
8 canceled our contract. That extremely prejudicial canceling of Foget as Aveggios replacement,
9 after Remington had spent MANY thousands of dollars on his education about the case, his role,
10 Aveggios documents, plans and the site, was just another example of Gans extortion, intimidations
11 and slander of Remington and Gans improper influencing of Jeff Nelson which resulted in the
12 removal of Foget, at extreme prejudice to Remington, as explained further below under Nelson.
13 Simply put, Jeff Nelson seriously prejudiced Remingtons entire case by removing both of
14 Remingtons local Eureka environmental experts, and that was one of the first examples of Gans
15 serious witness tampering based on fraud, false innuendos, and extortion within the scientific
16 technician community, and/or wire fraud, by phone threats, and/or bribery. Tampering with Foget
17 through his boss Nelson also violated Remingtons 42 USC 1833 rights, which are also discussed
18 below.
19 G. The February 12, 2016 email chain to Gans, Plotz, et al.
20 Another deposition scheduling battle where Gans attempted to extort and intimidate
21 Remington and exerted his will as to scheduling, hours, days and duration, knowing that he could
22 influence this former law partner, Judge Reinholtsen and easily win his point, and perhaps get
23 Remington sanctioned in the process and get his case further prejudiced. Every motion in the last
24 two years has threatened and extorted Remington with frivolous sanctions.
25 Eventually, Judge Reinholtsen did make some very prejudiced judgments on Dr. McEdwards
26 and Ms. Hoyos, cutting out the latter entirely in effect and limiting the former to the meager
27 questions asked by Gans, which omitted 90% of his telegraphed testimony (which is all of John
28 Aveggios prior subjects and work) and Gans also mischaracterized the few remarks that Dr.
McEdwards did make to his limited questions.
39
1 This was another example of Gans illicit intentions and the effects of his action was to
2 prevent Dr. McEdwards from properly seeing Remingtons land, while hurrying-up from
3 Laytonville on an unacceptable schedule for Remington.
4 The overall effect was prejudicial for McEdwards visit, education and the overall effect on
5 Remingtons case. Although not arising to direct fraud necessarily, overall these emails intimidated,
6 extorted, embarrassed and upset Remington and his expert preparations and generally disrupted
7 Remington civil rights, rights to due process and overall was an obstruction of justice under the
8 color of an officer of the court, who also happened to be a former law partner of the judge who
9 always backed Gans up. Said judge has now attempted to have been removed.
10 H. The October 13, 2015 letter and email, never sent in the mail as promised, withdrawing the
11 deposition notice of de-designated expert Foget. This was nothing more or less than an unfair,
12 fraudulent act of intimidation and/or extortion to try and break Remingtons resolve over having his
13 only environmental expert die, and Gans tried to make his replacement McEdwards) impossible at
14 first, and then difficult and unwieldy as his next obstructive effort.
15 First, Defendants threatened to call Remingtons de-designated expert when his boss, Nelson,
16 had withdrawn him, from the case. Gans unethical plan was to threaten to call Foget at trial when
17 he was not allowed to testify or be Remingtons expert any further, and had Gans plan gone
18 through as schemed, Remington would have had no trial expert. This sort of behavior from Gans
19 has been going on for years and has made Remingtons litigation very difficult, however these dirty
20 tricks and tactics are not illegal and in violation of federal law, youre just mentioned as background
21 concerning what goes on here. As has been explained elsewhere, most of Gans litigation strategy is
22 unethical and unfair but only 10 to 15% is actually corrupt, illegal and/or in violation of state and
23 federal laws.
24 Second, defendants called Remington a liar about Foget being used at all to read or interpret
25 Aveggios testimony, as originally planned and expressed, nor would defendants allow Foget to
26 even authenticate Aveggios handwriting, however Judge Reinholtsen has killed that possibility
27 already or indicated that he would have, even if Jeff Nelson had not (already) conspired with Gans
28 to remove Foget and all Eureka experts from Remingtons case.

40
1 In general, these threatening, nasty letters from Plotz and Gans were perceived as and
2 intended to upset Remington, break his resolve and extort him to end the lawsuit, settle for zero,
3 and take nothing, in effect. Recall, that the background for all of these communications was a
4 continuous never-ending series of felony vandalisms from Mathson, and every day it was tempting
5 to end all this pain and move on to something else.
6 That has been defendants pattern here for the last four years, which coincides with the
7 criminal extortive RICO racketeering enterprise complained of herein.
8 I. Next, see the combative October 6, 2015 email wherein Remington alleged no meeting and
9 conferring on anything, yet again, as per several previous serious transgressions of that in
10 previous years.
11 You have no conceivable good faith basis to seek to augment your expert witness list yet
12 again, which is a direct LIE in contradiction of the clear CCP statute which prescribes that a dead
13 expert can be automatically replaced. Defendants know the law as does Remington also, yet they
14 fraudulent misquoted it to attempt to deceive Remington and the court, and to commit what appears
15 to be additional RICO extortion.
16 J. Finally, Remington alleges that many of defendants MILs were deliberately fraudulent,
17 based on false science, false law citations, false logic, apparent bribery (or the appearance thereof)
18 of Judge Reinholtsen and were generally knowingly without merit. E.g. MIL #2012, where Gans
19 wrote: for a continuing nuisance, release is limited to damages for the loss of use of the property, if
20 any, during the three-year statutory period., citing Santa Fe v. Arco, and omitting the crucial fact
21 that reasonable remediation costs are also recoverable, mandated and are almost always the primary
22 damage requested and granted.
23 K. Remington alleges that there are another dozen or so examples of mail and wire fraud in
24 the documents scattered around his offices and in his files, which he will organize and review
25 before the FAC is due in this matter, at which time it will draft an augmented, streamlined and
26 condensed version of this RICO statement to accompany it.
27
12
See June 4, 2016 email with federally relevant attachments which were fraudulent, wrong and disputed documents
28 from Schwartz, Ferriman, Gwinn, Gans, etc. and these were all sent by mail and wire, are fraudulent by either
method, and were knowingly misleading to Remington and an attempt to deceive the court, all in violation of State
and federal law.
41
1 4. Obstruction of Justice by Gans, 18 USC 1503.
2 Introduction. Gans has no honest scruples or ethics and has become a feverishly involved
3 player here since about 2014 and his plagiarism of a federal judge because he was desperate and
4 had nothing factual or credible to defeat Remington with. Gans activities departed from the
5 unethical and over-zealous in 2012-14 when he paid and encouraged his County superior Court file
6 room saboteur to separate, scatter and ruin many of Remingtons contientious lengthy filed
7 documents, and several searches never confirmed that said documents reached their proper judges
8 and courtrooms.
9 (A) Gans crowning CRIMINAL achievement to date was his surprise horrific suborning of
10 perjury among his 5 chief SOL trial witnesses, as discussed. He acknowledged wood-shedding,
11 lecturing and fully indoctrinating and coaching his SOL trial witnesses at Voir Dire in August
12 2016 and gathered a jury which condoned that and did not know that it actually meant wring a
13 perjured SCRIPT for 5 witnesses. Even R did not anticipate Gans total corruption and
14 abandonment of all truth. Any case is harder to win if the other side can say anything, get 5
15 witnesses to swear that black is white and make it stick as occurred here. Gans is the ventriloquist
16 controlling a room full of dummies in all capacities, especially his experts, which are now
17 abandoning ship, making trying the contamination cases problematic and likely impossible for
18 Gans.
19 Better Call Saul is where Gans is today, a criminal lawyer in all senses of that phrase and
20 who eventually should be convicted of being a North coast Godfather, at least as related to THESE
21 cases if not his entire practice.
22 (B) Another major crime committed by Gans on February 14-15, 2016 was to alert his soldier
23 John Mathson that Rs replacement expert Dr. McEdwards was coming-up from 3 hours away for
24 a deposition and first and only site visit. Gans told Mathson, and instructed him what to do.
25 Surveillance video shows Mathson purposefully, methodically and FRANTICALLY following
26 orders by raking-up redwood needles in an unlikely area good for ONLY that, and spreading them
27 over all asbestos pipes on the site to give the appearance of a benign UNCONTAMINATED
28 pristine forest area, simulating a Love Canal.

42
1 1. Gans and Mathsons purpose was clearly to misrepresent the truth to Dr. McEdwards, and
2 knowing what McEdwards had NOT seen on the dump site a few minutes earlier was clearly
3 implicit in Gans questioning. To Dr. McEdwards it looked like Remington had been
4 misrepresenting the scene with doctored photos from 2008, when it was actually Mathson and
5 Gans, who is on video surveying Mathsons progress at broom-sweeping the dumps surface, who
6 severely and feloniously altered the crime site, removed, concealed and falsified evidence to
7 prejudice Remington and benefit themselves. That is similar to OJ going to Bundy a few hours after
8 the murder and doing his civic duty of hosing-down the site and removing all BLOOD and clothing
9 before it started to stink. That would be unlawful just as Mathsons and Gans intentional evidence
10 tampering here.
11 2. Gans thus ORDERED and encouraged Mathson to spoil, alter, remove, conceal and
12 DESTROY material evidence, however happily our very complete site photos from 2008 and yearly
13 thereafter can prove what Mathson did, WHEN he did it, HOW in most cases and WHY. Gans has
14 obstructed the due administration of justice in Department 8, falsified evidence to defraud the
15 Court and r and then lied about it. However, by apparently having Judge Reinholtsen in his
16 pocket as appearances infer, NONE of the above when complained of to Judge Reinholtsen
17 received any reaction or admonishments to Gans or Mathson who sat there 20 from the Court for
18 90 days like Remington did.
19 SPECIFIC EXAMPLES OF GANS OBSTRUCTION OF JUSTICE VIOLATIONS OF
20 STATE AND/OR FEDERAL LAWS:
21 A. Penal Code. 526 PC and 527 PC violations. Gans December 2014 plagiarized false
22 quotes of a Federal Judges SJ Orders and dicta, simulated a Federal Court Summary
23 Judgment ORDER from Judge Vadas, to falsely obtain an erroneous collateral estoppel
24 ORDER against Remington in Judge Reinholtsens state court proceedings, a year later.
25 Gans fraudulent material plagiarisms of the central issue in the cases, and multiple, unlawful false
26 quotes of a federal judge at state CE SJ, may not be a federal crime, but appear to be state crimes,
27 as defined by PC 526-27. Gans false Federal Judge ORDER simulation certainly confused and
28 deceived Judge Reinholtsen, mostly because Reinholtsen trusted Gans as a former law partner and

43
1 fellow member of the California bar and officer of the court. Now we see that Gans is more than
2 that, or at least a lot LESS than that.
3 The above transgressions, detailed specifically elsewhere and in 200 pages in 2014 SJ
4 Oppositions, show Gans ethics, motivation and MAY be considered by this court in evaluating
5 whether a hated pro per can be allowed to go after and avoid dismissal at the pleading stage, let
6 alone accomplish the unheard of and nearly impossible task of sending a mighty (alleged) officer
7 of the Court to prison and disbarment. Remington thinks the overall deceitful pattern of a
8 criminal enterprise is obvious in the entire gestalt, if looked at honestly, dispassionately, in full
9 DETAIL and objectively.
10 Judge Reinholtsen initially denied CE SJ, without sufficient understanding of the case law or
11 philosophy and for he WRONG reasons, so eventually when pressed and probably influenced
12 somehow, he forgave and forgot Gans criminal writings, and lost touch with justice and logic, in
13 Plaintiffs view.
14 B. In January-February 2014, Gans 170.6 disqualification of Judge Miles was not a federal
15 crime, obviously, but in this context that disingenuous removal greatly PREJUDICED Remington
16 and the TRUTH HERE, and was MORE THAN a mere legitimate tactical litigation measure to
17 aggressively represent his client. Gans is REALLY the client and makes his living off these cases
18 and intends to continue that indefinitely. Gans FANS the flames and everything he does is intended
19 to add another few months to his endless gravy train. HERE, Judge Miles remembered the
20 Mitchell firms blatant, unconcealed corruption from her analysis of Gans and Brissos inflated
21 special motion attorney fees, billing Remington for dozens of hours spent working on other issues
22 and clients, double billed R for motion fees UNRELATED to the special motions and GROSSLY
23 exaggerated their hours spent, as analyzed above, and summarized in her reduction of their
24 Lodestar fee request by more than 80% overall.
25 On the street or in Remingtons real world of ordinary ethics and reasonable logic, the
26 Mitchell firm are merely extorters, burglars and street THUGS, but HERE they are treated like
27 officers (of the Court, supposedly), respectable advocates and royalty, which will stop when, or
28 IF, some court LOOKS closely at Gans again especially, just like Judge Miles looked at Gans AND
Brisso in 2009, when BOTH came-up CROOKED, muttering like Nixon, Im no crook.
44
1 Arguably, Gans and Brisso committed multiple mail frauds in sending the above, and literally
2 hundreds of mailings involving various degrees of fraudulent issues, discussions of them and
3 omissions of virtually all just and accurate facts, in an 8-year, so far, materially and ethically
4 fraudulent barrage of documents to Remington and the Courts. As above, EVERY document Gans
5 sends is not a mail fraud, but MANY ARE. HOW many are too many for a California lawyer?
6 Pretty many are tolerated, allowed and acquiesced to obviously, especially with a judge who is
7 under possible indictment for ethical frauds and embezzlement himself.
8 More relevantly, Gans often goes up to 30 days, during stays, lulls or awaiting crucial
9 decisions or appeals without committing any frauds in THIS case, but in OTHERS? THAT will be
10 checked by someone, because a THIEF or psychopath really cant control himself at some point,
11 which R believes has happened here.
12 C. Specific multiple prejudicial instances of 1503 FILE ROOM Obstruction of Justice
13 occurred in December 2013-January 2014, violating Remingtons due process rights in state court
14 and nearly causing his just cases to be DISMISSED 4-5 times due to non-oppositions or missed
15 filing deadlines for every type of document, including Summary Judgment Oppositions, as HERE.
16 During the Christmas 2013 confusion, The Mitchell firm and/or (still unknown and uncaught)
17 Mathson Court house saboteur (discussed above) separated Remingtons major 1000+ page
18 document packets and made Remingtons Oppositions unintelligible in two courts. 50-pages have
19 been written about this, omitted here. Gans has a paid spy in the file room or regions and
20 repeatedly has masterminded frauds on Remington, tampered with his filings in MANY egregious
21 ways plus related timing, technical and administrative ploys and dirty tricks, all of which
22 GREATLY damaged Remingtons Burl Tree defense by tens of thousands of dollars, in time, costs,
23 emotional stress and Harvey Roberts time paid by Farmers.
24 D. Count #2 of 1503 FILE ROOM Obstruction of Justice. MANY other related felonious
25 tampering with State civil procedures and justice took place there, e.g. the October-November 2013
26 discovery that Remington had been deliberately REMOVED from the Courts service list, since
27 about 2011, resulting in Remington not receiving any Court decisions for more than a year, of
28 active court ORDERS and decisions, including several CRUCIAL ones, such as Judge

45
1 Reinholtsens 2011 SJ decisions and requests for additional briefing, which Remington never got,
2 never saw and NEVER DID.
3 There have been about a dozen KNOWN incidents of document tampering, unreasonable
4 delays for top clip issues where documents were HELD in the file room until two days before a
5 crucial hearing for example, around 2011-13 that happened a lot, and then returned to Remington
6 one day before a hearing for corrections, when the Court assumed that no opposition or initial
7 motion had even been filed, etc. HIGHLY troublesome, traumatic and PREJUDICIAL to any
8 litigant especially a contientious pro per. This issue has been taken-up repeatedly in written
9 complaints since 2009 with various court executives, who have mostly GONE now, and has also
10 been directly addressed and discussed in open Court in Department 8 on at least 4 occasions, most
11 recently in May 2016, below.
12 E. Count #3 of 1503 FILE ROOM Obstruction of Justice. Actually going-on for MANY
13 years, since at least 2011, around May 1, 2016 a crucial SEVERANCE hearing was cancelled
14 without notice or authority by someone at the courthouse.
15 Remingtons attorney (2009-2016) Harvey Roberts was holding on the phone and Remington
16 was in the courtroom, but the issue and crucial hearing had been taken-off calendar by someone,
17 so it was never held. Gans did not want that severance hearing to go forward because his entire
18 enterprises strategy depended on subterfuge and keeping his frivolous case BLAMING Remington
19 for all contamination on both sites, despite the scientific and logic absurdities and physical
20 IMPOSSIBILITIES of that mischaracterization possibly being true. DID GANS ARRANGE TO
21 CANCEL THAT HEARING? Remington thinks so, but no one can ever prove anything around
22 there.
23 Coincidentally Gans was also frantically negotiating with Remingtons side to settle-out
24 his frivolous visual nuisance case against Remington. The delay in the SEVERANCE hearing
25 which Remington had briefed WELL and convincingly, played right into Gans hands (why is that
26 not surprising?) so he had time to extract another $10,000 from Farmers from where he was the day
27 the Severance hearing had been scheduled! Around the Eureka courthouse, CRIME PAYS, BIG!
28

46
1 A federal predicate act, likely NOT, but we only need two and have over 20 that should
2 suffice, federally, whereas the other continuous corruption, dirty tricks, lies and deceptions just are
3 part of the racketeering enterprise, as discussed.
4 F. Gans creates his perfect fictional Twilight Zone witness, Peter Esko, obstructing justice
5 and INVENTING and writing a script for a bogus, phantom non-existent witness appears to be
6 tampering with a witness, if not worse. This on-going saga, which Remingtons witness in the
7 Humboldt Health Department says will never testify about anything, violates 18 USC 1503 and
8 1512, plus 1341, at least 10 times. In about fall 2013, the contrived, LAFCo connection between
9 Brisso and Martel, Director of Eurekas Department of Environmental Health created the surprise
10 Peter Esko enigma to inexplicably exonerate the Mathsons massive residential hazardous wastes
11 dump.
12 Also, coincidently justified and pardoned in Gans brilliant illicit plan was the blessing of
13 defendants contamination of Remingtons land, all Mathsons extortive related vandalisms,
14 evidence spoliation, racketeering, extortion, etc. Esko resolved everything, supposedly, based on the
15 one-sided, also Gans ghost-written fraudulent 123-page Blue Rock Report, too long for anyone
16 to read and refute, except for John Aveggio.
17 The evidence proves that Esko was a corrupted member of this enterprise and never was a
18 credible scientific expert. Remingtons witness indicate he is believed to be a bribed or corrupted,
19 and in any case a fabricated, BIASED, one-side only, proselytizing, irregular witness fictionally
20 created by Brisso and Gans in collusion with Dixon and Melissa Martel to fill a gaping hole in
21 Gans defense.
22 Creating a major, star witness to fill a needed role, and fabricating his entire report, which
23 was based solely on Gans bribed experts Ferriman and Gwinn in the first place, whom Gans had
24 already written THEIR expert reports for them, would be a joke, except this was SERIOUS! Two
25 different state judges took Eskos creation and expertise as a given and were prepared to allow Gans
26 to use him to con and deceive the jury as to his veracity and credibility. HERE, however,
27 Remington will attack his report, reduce its significance and relevance here to absurdity and depose
28 him, IF he is even still in this country, as he retired years ago from working for the County and is

47
1 now just doing Martel, Brisso, Gans, et al a FAVOR, and being highly prepared for that favor, if
2 he even shows-up at all, which as above, is gravely in doubt.
3 G. More 18 USC 1951 and 1503 violations. From 2008 to January 2017 (so far), John
4 Mathsons extortive felony fence, equipment, window and garden VANDALISMS kept the
5 enterprises pressure-on daily, especially around state case filing deadlines. By 2013, every time a
6 major multiple hundred page document final was imminent or due for final drafting and word-
7 processing, during the last few days Gans would always notify his soldier and ventriloquists
8 DUMMY Mathson and tell him to open up the gates and flood Remingtons land with deer and
9 vagrants. Therefore, as Remington came in the gate he could almost expect to see 3-4 big deer
10 meandering amongst the weakest roses as if they owned the place. Looking for the Mathson holes
11 and then arranging for a dog to chaise them away usually took 24 hours in most cases, in most
12 years, and distracted Remington considerably in the meantime. Probably only a jury could evaluate
13 the significance of those hostile, sadistic intentional acts and place a dollar value on that to the Burl
14 Tree and measure the emotional toll on an old guy in his mid-70s. Remington keeps business
15 records of most significant acts and events here and when required can provide endless details on
16 top of THESE documents documenting the time, place, damages and photographs of same in many
17 cases as Remington is a SERIOUS photographer with professional skill, equipment and graphics
18 capabilities. Again, as above, today (11-16-16) the new gate damages in two places were
19 photographed about 9 times, including before and AFTER repairs. Assuming only one deer entered
20 after dark, and then left by afternoon (it is not known whether the deer is still HERE or not, and
21 only tracks and a few days will determine that), probably in THIS season, only misdemeanor
22 damages of $1-200 of delicate roses and Japanese maples, rare Fuchsias, etc. were eaten
23 and ruined today, a pretty GOOD day here.
24 H. 18 USC 1951 (extortion) and 18 USC 1512 (witness tampering) by RAO on Marsh.
25 On (and prior to in planning meetings) November 14, 2015, Wayne Marsh, replaced the
26 scared-off Figas, at Figas request, becoming Remingtons new excavator operator and remediation
27 contractor expert witness. However, RAO heard about that from Figas, in an as yet undetermined
28 manner, and Marsh was then similarly bribed, threatened, coerced, intimidated, extorted or even
possibly blackmailed into NOT showing-up for work, to do the job he had just promised the night
48
1 before. We went over all details (again) Friday evening, but 12 hours later RAO reached marsh and
2 prevented him from working here, just as they had with Figas. That Saturday the rains came-in and
3 washed-out the job for another year.
4 I. 18 USC 1503, and 1512 Obstruction of Justice, and altering, destroying, mutilating
5 and concealing evidence to prevent its use at an official proceeding, here several TRIALS, in
6 and prior to 2015. Specifically, as per surveillance video proofs, in December 2015 and into
7 March 2016, in a major felonious manner, John Mathson continued Gans major stealthy vandalism
8 and evidence spoliation and REMOVAL program, wherein the CONTAMINATED HAZARDOUS
9 DUMP SITE on Rs land now looks superficially remediated. Detailed surveillance video footage
10 exists, from multiple cameras and angles of John Mathsons trespasses through his secret doors,
11 gathering and dispersing redwood needles and rolling, lifting and disposing of asbestos pipes into
12 his double-gated secure storage areas, during this period.
13 1. Like broom sweeping a nuclear radioactive spill, what John Mathson has done and continues
14 to do here is to conceal and disguise deeply buried hazardous debris and pretend the invisible
15 vapors, dusts and microscopic airborne Chrysotile fibers dont exist. Gans smart purpose became
16 clear in May 2015:
17 2. To a jury and ordinary people if it looks messy it probably is contaminated, and if it
18 looks clean, well-kept and BROOM SWEPT then inferentially it IS PRISTINE and
19 uncontaminated! Hell with the scientific tests, what do they show and what do the guys with
20 thick glasses know? R had requested a jury visit around January-March 2016 to view first hand
21 what the 2008-11 photos showed: massive contaminated and adverse debris on the lands surface,
22 which extended 10-15 deep. Removing the surface debris and covering the emerging 15,000#
23 concrete blocks with redwood needles and orange wild lilies gave the sites the appearance of a
24 normal redwood forest again if you did not look too closely. When the jury visited they would see
25 nothing, because John Mathson had REMOVED by hand and covered virtually all visible
26 contaminants, covered he huge immovable and unbreakable objects with organic materials or
27 broken-them-up smaller, such that most contamination was concealed in dirt-and brush covered
28 piles 15 deep, but looked clean on the surface. Whats a jury going to believe: its EYES or some

49
1 lying experts, tests and old obsolete 2008 photographs that may have been altered according to
2 Gans?
3 3. Altering a crime scene is a felony in most cases, although California SC state law has become
4 ambiguous and favors sanctions over prison sentences. However, if OJ had removed the bodies,
5 wiped-up blood on gates and driveways and then hosed down the concrete for 2-3 hours BEFORE
6 the police got there, that would appear to be a CRIME. Here, Mathson did just that but for years,
7 and especially for 3 months in winter 2016, when several experts (from BOTH sides) were invited
8 and imminent, many new current photos were being taken and a jury and judge were about 60%
9 likely to be arriving for a detailed close-up site inspection. [At the moment Judge Reinholtsen has
10 stymied that request, but that could change.]
11 4. To Remington, what John Mathson did is felonious evidence tampering to eliminate most of
12 the visual evidence against him in a visually based case! As a result, Remington is requesting
13 terminal evidentiary sanctions against Gans and Mathson and a declaration that liability is
14 established and the 2008 photos and depth tests are now proven, established and stipulated. In other
15 words, defendants have to REMOVE everything they placed here. If they want to swear that they
16 cleaned-it-all up and little remains that is fine, but ONLY if they agree to now start DIGGING and
17 keep removing the remaining millions of pounds of hazardous wastes until NOTHING remains
18 except pristine redwood forest loams.
19 J. 18 USC 1503, & 1512-13 More Gans Obstruction of Justice, in this case; altering,
20 destroying, mutilating and concealing evidence to impair its integrity, REMOVE it entirely
21 and/or prevent its use, in any case at the several scheduled and future trials herein, this count
22 referring specifically to January until May 5, 2016, and Remingtons evidence for that period.
23 The above described evidence tampering continued seriously, and differently in some
24 respects, into February-April and Remingtons experts depositions and site visits, greatly confusing
25 and minimized the visual impact of site visits and reduced the value of the evidence photos from
26 2008, to near absurdity, in that they now require an explanation from Remington, and ONLY he can
27 do that. John Aveggios death and Fogets removal have left Remington with no one who can fully
28 and emphatically VOUCH for what was and IS still there, buried deep under dirt and concealing
debris.
50
1 Mathsons tampering and removal of evidence (from the murder site, so to speak, of the
2 land) was well-captured on surveillance video prior to March 2016. Recall that Mathson never
3 operates on his own initiative and only under Gans orders and legal clearance, and Gans closely
4 monitors and frequently is seen on surveillance video, surveying, managing and checking-out
5 Mathsons work on these dump sites.
6 After the above detailed pretrial hearing discussions about exactly what Remington had on
7 his surveillance videos, thereafter John Mathson was much more careful and circumspect, because
8 Remington complained every other day about his vandalisms and spoliation in our 3-hour pretrial
9 hearings lasting about 100 days, and perhaps unwisely pretty carefully explained his surveillance
10 systems to the Court with Gans and John Mathson sitting THERE at the table only 15 away, daily.
11 Not surprisingly perhaps, thereafter, the GOOD criminal acting by John Mathson in Remingtons
12 outdoor property surveillance videos ceased.
13 K. Massive Gans pre-trial hearing 1503, et seq pretrial lies, mischaracterizations,
14 perversions of justice, deceptions and frauds on the court, as cited throughout this document.
15 In May-August 2016, Gans committed about 90-days of serious pre-trial deceptions,
16 mischaracterizations, disingenuous MILs, a few actually legitimate and mostly accurate
17 evidentiary positions plus many actual lies under oath, as explained in thousands of pages
18 elsewhere, and summarized in the next paragraph below. Judge Reinholtsen presided every morning
19 from 8:45 until 12 noon for 3 months, generating a massive but expensive 250+ hour
20 stenographic record, where Gans was sworn to be a truthful officer of the court, but did not worry
21 at all (then) about that being enforced.
22 Mischaracterized and or perjurious topics by Gans and Plotz included without limitation:
23 Ms twin 6 drain pipes, Schwartz late investigations, multiple deceptive MILs, incomplete,
24 frivolous or bad faith FALSE case citations on all topics, prejudicial, improper photos and biased
25 out-of-time exhibits, surprisingly allowed by Judge Reinholtsen, BAD SJIs and eventually major,
26 multiple (5 witnesses) suborning of perjury.
27 Also, during this period, Plotz and Gans reinitiated their frivolous malicious prosecution
28 cross-complaint cause of action against Remington. DENIED in fall 2015 by Judge Reinholtsen as
obviously frivolous under the well-known facts, but reinstated in DR140426 as a pure EXTORTION
51
1 action against Remington in early 2016, which will be the subject of a slam-dunk 425.16 ANTI-
2 SLAPP Special motion, imminently. DR140426 as been continuously stayed since that cross-
3 complaint to the disappointment of two different attorneys, interested in getting-in on anti-SLAPP
4 motion attorney fees. HERE, they are a guaranteed slam-dunk. Judge Reinholtsen has ALREADY
5 rejected it; the initial federal suit the subject of Plotzs motion was approved and initiated by an
6 attorney, in other words PROBABLE CAUSE was demonstrated by a skilled attorney in the area and
7 the suit was not some dumb pro per mistake, gone bad; and FINALLY and just as important:
8 Federal Judge Vadas exhaustively examined and analyzed all of Remingtons initial 2009 federal
9 evidence, and allowed the case to go forward, EASILY without reservations, in a long detailed
10 ORDER. If attorneys and judges found probable cause, who is young Plotz to say it was
11 always lacking? It was always there, and the record shows it is STILL there, but for Remingtons
12 unfortunate Rule 26 disclosure errors in 2011.
13 In the overall PATTERN herein, this was a predicate act. Not a HUGE, egregious one but
14 another extortion and intimidation to advance ALL the enterprises objectives in one lawsuit, where
15 THEY make money off their egregious contamination! What a weird justice system where that is
16 even conceivable! Ruin someones land and do $600,000-millions of dollars of damages and then
17 trick, sue, defraud and swindle the poor victim!
18 L. 18 USC 1503 and 1512, Obstruction of Justice and Witness Tampering by Gans.
19 The weekend before the SOL trial started, Gans wrote a simple false, perjurious script for
20 his ventriloquists dummy. Gans elaborate, 2-3 months in the making and daily intense rehearsals
21 of John Mathsons central perjury in the SOL case were viewed by Remington for at least an hour
22 per day for 100 days in 2016. To and from the courtroom, in the elevator, before the courtroom was
23 unlocked and for 20 minutes of breaks each day, Gans was constantly discussing this case and John
24 Mathsons star role in it, endlessly rehearsing the false, fictional facts on the central issues. John
25 Mathsons resulting calm, psychopathic LIES about walking the fill with Remington in 1998, NOT
26 JUST ONCE but TWICE, were therefore well rehearsed, executed, shocked and surprised
27 Remington at Opening Statements in their brazen illegality, desperateness and brassiness, and hence
28 were not fully refutable, on the fly in 5 days of cross-examinations. The Court was not helpful
either, however Remingtons cross-examination experience was lacking as was his organization to
52
1 meet such overwhelming perjury. Said perjury simply involved his word against a personable Gans
2 plus 5 ordinary Eurekans, and the jury proved to be MORE like the 5 perjurers than Remington in
3 education, temperament, class and disposition, and thus believed the later. Gans eventually WON
4 the SOL trial unanimously, because the jury liked Gans and his witnesses and not the old pro per
5 Remington and his slower, uneven, complex presentation, where the jury instructions were
6 inadequate and ERRONEOUS instruction to them in Remingtons opinion.
7 Remington had not gone near Mathsons land in 1998, or ever spoken to him on it at all until
8 after 2004, but the jury WRONGLY believed Mathson, which shows no system is perfect or even
9 close in this case, against a RICO enterprise and overwhelming intellect and financing.
10 M. 18 USC 1511. Obstruction of law enforcement by Gans, et al and his racketeering
11 enterprise, as relating to a gambling endeavor, pertinent here and fitting federal statutory criteria.
12 RAO, Mathson, Gans, Lawrence are the primary racketeering leadership presently (with Kluck and
13 others soon to gain GREAT importance) and THEY have gambled, and continue to roll the dice
14 daily that Remington would never discover their buried criminal secrets, and John Mathson
15 continues removing and covering (with redwood needles) new evidence daily as it emerges to
16 minimize accurate photography and impact. Said defendants now have at least one million dollars
17 at stake here on the craps table and have bet they can keep Remington and the State judge the
18 Honorable Dale A. Reinholtsen at bay here, away from REAL knowledge and discovery and then
19 OUT WAIT Remington and hope his health slips further to where he can no longer breath and fight
20 this injustice. The exact definitions of 18 USC 1511 (b) which define a conventional 1950-1990s
21 gambling business ALSO fits these facts perfectly. Therefore, all definitions and criteria being
22 MET 100%, Remington elected to cite this statute perhaps creatively, however it FITS, and see
23 also 1955. The above million dollar gamble has been going-on since 1998, but CONTINUES
24 in every parameter, and THIS is a continuing case, because it was timely filed and ALL criteria of
25 California state continuing nuisance/trespass are met, and presumably the same criteria apply
26 federally, as to the continuing federal allegations.
27 Obstruction of state law enforcement of gambling is defined in this statute. Gans criminal,
28 residential eureka dumping and concealment racketeering enterprise was not a conventional book

53
1 making, numbers or illicit betting operation open to the public like those that existed 50 years
2 ago, when the laws were conceived.
3 Nevertheless, Gans has a "gambling operation here now based-on the original RAO-
4 Mathson gamble to violate over 50 laws when they originally imported their hazardous and
5 controlled materials here, buried them and further concealed them on their neighbors land,
6 Remingtons, and then getting away with all that for about eight years. They escaped notice,
7 scrutiny and investigations for eight years and now have developed a huge, ruthless no-expenses-
8 barred, no litigation ethics or morals, cover-up, complained of here. This enterprise was an
9 innovative, novel form of gambling, 1990s style and meets all the statutory criteria of 18 USC
10 5011 (a) and (b).
11 (a) Under 1511 (b) (1): an illegal gambling business means a gambling business, which is:
12 (i) a violation of the law of a state or political subdivision in which it is conducted;
13 (ii) It Involves five or more persons who conduct, finance, manage, supervise, direct, or on all or
14 part of such business; and
15 (iii) Has been or remains in substantially continuous operation forward. In excess of 30 days or had
16 a gross revenue of $2000 dollars in any single day.
17 Those three criteria are very easily met in this case. For example, here:
18 (b) Defendants had and still maintain an illegal gambling business, and here:
19 (i) Defendants violated State law here in numerous ways by establishing a serious, highly toxic
20 hazardous waste dump in this residentially zoned single-family subdivision and redwood forest.
21 Given the fact that everything defendants have done here since 1998 was totally illegal and
22 in violation of more than 50 various types of laws, Gans primary leading effort has focused on
23 avoiding cleanup costs, making him money personally, minimizing enterprise expenses overall, and
24 keeping himself in his many enterprise members as possible out of prison. Clearly, what he has
25 done here for many years meets all criteria of an 1511 illegal gambling business.
26 (ii) Five managers supervisors and directors? Easily met, obviously. RAO's and the Mathsons' had
27 four (4) central managers: Olson, Skillings, John and Joy Mathson, and also used Costa and
28 Kishpaugh as needed, apparently, and also had another 5 to 10 employees and known independent

54
1 drivers involved including Joe Costa and Nichols Trucking. The second criteria here is also easily
2 met.
3 (iii) As described elsewhere this illegal hauling dumping a disposal operation around 1998-2000
4 lasted for several months at a minimum and had gross revenues of at least 20-$30,000 per day on
5 many days, so the $2000 minimum is easily met.
6 Additional details about this gambling business, which began before the formation of the
7 enterprise in 2012, however said gambling business continues to exist TODAY, but in somewhat
8 different form; however, its basic objectives (to punish, abuse and crush Remington, and The
9 Big House, avoid all costs, cleanup hassles and expenses, and to avoid fines and imprisonment)
10 have essentially not changed much, since 1998.
11 a. Paul Dalka was the key enforcement official involved in this project, representing the County
12 Health Department and the water board, who appears to have been bribed, because he looked the
13 other way wherever defendants were concerned, while strangely frivolously investigating
14 Remington in 1998-9. Melissa Martel and others locally also had knowledge of this project.
15 b. Other CHP and regulatory officials involved with regularly supervised gas station cleanups are
16 believed to have also assisted this massive illegal operation, before the advent of the enterprise, and
17 someone let about 400 large illegal truck loads pass along the roads, and/or slip-up Elk River
18 Road in daylight, apparently without any arrests or the problems that the normal logging truck
19 driver would experience, as discovery will confirm.
20 c. Olson and Mathson owned this gambling business and still do, and still shoulder the gambling
21 risks here, and it is now Gans that is protecting this very illegal residential class I dump by means
22 of his racketeering enterprises ongoing cover-up.
23 d. As documented elsewhere, ONE 10-yard dump load alone, of the 400+ involved, of hazardous
24 lead, asbestos, saturated hydrocarbon soils or biological wastes could save at least $2000-4000 in
25 hauling costs alone. It is expensive to haul 10-yard loads past Redding or to Nevada, taking 12-16
26 hours, or more. At $100 per hour RAO's saved lots of money by hauling for only 20 minutes round
27 trip, the barely 3 miles up Elk River Road to Mathsons dump, and back. Six minutes each way, and
28 another six minutes to dump it equals 18 minutes. Two minutes to talk and an RAO employee or

55
1 independent driver could easily do three loads per hour and save up to $10,000 in one hour! This is
2 a very profitable gambling business!
3 Other than Olson, Skillings, Mathson, Randall, Dalka, Costa and perhaps a few other drivers,
4 the true deep illegality of this dump was not well known to the present enterprise members until
5 about 2010-11. The Gans lead Humboldt Mafia-like racketeering enterprise now has at least a $1
6 million stake in preventing a costly cleanup, fines, treble damages and likely jail time for Gans, the
7 others named above and probably several others, including Plotz, Kishpaugh, and perhaps even
8 Nelson, according to discovery, proofs, conspiratorial connections and trial.
9 It is now feared that defendants will determine that they only need to silence Remington and
10 somehow force him to give up the lawsuits, and the fight, and just obediently sell out (for 20 cents
11 on the dollar), leave town or die quietly. Gans is ruthless, as are his two primary enforcers: Kyle
12 Skillings and John Mathson.
13 Both have tried hard so far to terrorize Remington, but without substantial success. Physical
14 violence, total arson or worse, must be in their minds, preparations or plans now because DEFEAT
15 is plainly not an option for Gans, Mathson or the enterprise, and Gans especially controls 95% of
16 the evil that occurs here.
17 Similarly, 18 USC 1955 prohibits an illegal gambling business as outlined above. Saving
18 five (5) pages now, we will analyze the 1955 facts applicability here in subsequent documents such
19 as during the Opposition to defendants Motion to dismiss this complaint.
20 N. 18 USC 1512, WITNESS TAMPERING. This is a BIG ONE. Arguably Gans
21 favorite, most successful deceitful, federally ILLEGAL device is to write the script carefully for
22 each witness to fit his FALSE facts, HIS NEEDS and what the witnesses integrity and degree of
23 conviction and memory is on each issue, (usually near ZERO in August 2016) which Gans plans to
24 call on them to gradually and falsely FILL-IN the painting, as it were. Gans has personally
25 violated this state and federal law in the state case DR 080678 pretrial and in the 2016 SOL trial in
26 literally dozens of ways, as now cited specifically.
27 1. Gans criminal RICO conspiratorial enterprise was not begun in its present form until about
28 December 2012, and it was not recognized as a criminal organized crime-like RACKET until 2013-
14, or in its present totally transparent structure until September 2016. The criminal cover-up and
56
1 the enterprises OBJECTIVE, purpose and total overt, dedicated attempts to DESTROY Remington
2 no matter what means were required, whether extra-legal perjury, obstruction of justice and
3 extortion, ETC it took, did not clearly manifest itself until a known day in late July 2016. During
4 that day, determinable from the pre-trial hearing notes, if relevant, Remington unfortunately
5 revealed his plans to the Court, with Gans sitting 5-feet away, and his specific photographic
6 methods of destroying their only partially credible statute of limitations witness Skillings. The
7 judge was not impressed probably, and did not understand, but Gans DID and was VERY
8 impressed. WHEN Gans heard he had NO CASE thereafter, he desperately spent a week (which
9 fortunately for him coincided with several days off for Remington to go to Oregon, etc.) coaching 4
10 witnesses to back-up MAIN BOSS PERJURER John Mathsons bogus, scripted story, never
11 revealed in Discovery or ANYWHERE until opening statements in late July 2016. Throughout
12 2015, Remington navely believe Gans would pretty much stick to the truth, as articulated in the
13 previous seven years, but was shocked at the massive false fabrications of all material testimony
14 and evidence beginning in early 2016. Gans subordinating perjury in five prominent witnesses was
15 the shock that opened Remingtons eyes to this entire RICO conspiracy and its vast rotten
16 corruption. Remington wont fall into that trap twice.
17 2. Today, as per this complaint, RICO Statement and charts, we can clearly identify about 35
18 conspirators involved in the overall cover-up, most of whom may just think they are doing their job
19 or duty against the hated, slandered Remington, who Gans portrays as analogous to the devil,
20 which eventually will be reversed into what is TRUE here, likely imminently in the press.
21 Inferentially, and subject to Discovery, only a FEW of the 35, including the attorneys,
22 Lawrence, Mathsons drinking buddies and the RAO bunch really know the full, illegal
23 DEPTHS which Gans has sunk the enterprise to. A very select few others, the REALLY good
24 people, if any, have LEFT Gans conspiracy previously, people like Hubbard, (known) and
25 conceivably Ferriman (unknown), who refused to obey all of Gans evil orders previously, are the
26 only two who come to mind as possibilities at this premature moment. As explained elsewhere,
27 there are a few other present enterprise members who may be waffling and may possibly become
28 states witnesses in a criminal trial, to avoid fines for present time. Plotz is the only name that
occurs in that thought, at this moment. He is kind of young, green, and nave to go down with a
57
1 criminal mastermind such as Gans, this early in his career. BUT, he does know right from wrong, he
2 knows Gans has suborned extensive material perjury, and if he doesnt turn against Gans and help
3 the DA, then he is equally as guilty as Gans at this point.
4 3. Those 2016 state SOL trial proceedings, depositions, declarations, transcripts and coached
5 perjuring witnesses are now relevant and admissible here, if Remingtons pendant state claims are
6 adjudicated here simultaneously and cumulatively as requested.
7 No SOL trial witnesses were (or are) exempt from these accusations and therefore include
8 everyone that they used: Costa, John Mathson, Skillings, Kishpaugh, Pulley and Gans, in various
9 capacities.
10 Their other witnesses were available for backup of the aboves perjury including Randall,
11 Olson and Joy Mathson, to name a few, however they were not needed this time. Gans has many
12 others who would have committed perjury, and presumably will in the future swearing to anything
13 Gans writes for them and coaches them on.
14 All of that substantial state trial perjury seems relevant here now, but if not, it will be at the
15 federal trial and all Remingtons perjury, collusion and conspiracy allegations will be anticipated
16 now in written and oral discovery here, questioned thereon, and logically set-up and detailed far in
17 advance, such that none of them will be able to keep their consistent false narratives in the next
18 federal trial. That especially applies to John Mathson who was the chief perjurer in the 2016
19 SOL trial13, and the three other major perjurers merely falsely confirmed Mathsons perjury and
20 that Remington was supposedly there twice on Mathsons site to conduct nonexistent conversations
21 with John Mathson, which presumably would have been about what John Manson said they were
22 about had they occurred at all, which they did not. NOT Twice and not once either. A bit hard to
23 explain here in a few words, however the resulting damage to Remington and the SOL trial was that
24 Gans perjurers proved that Remington was lying and not Mathson, and that cost Remington
25 the entire trial, due to the BAD jury instructions, which might well have very severe damages, and
26 may still cost Remington his entire state contamination case.
27 13
Fortunately for Remington, when John Mathson gets tired he cannot keep his lies consistent and he gets rummy and
gravitates towards the default of honesty, which is anathema for Gans. He was caught once during cross-examination
28 while he was tired and he lapsed unexpectedly into INCRIMINATING TRUTH, however the jury didnt pick up on
it, and then the judge (Gans former law partner, now disqualified) quickly set-up a recess before Mathson buried
himself and the entire case in truth which would have led Remington to win in 2016, at the SOL trial.
58
1 4. So far Gans has procured PROVABLE perjury (Remington will use by omission cross-
2 examination techniques in the next trial), in the 2016 State SOL trial and Remingtons job here will
3 be to get all that repeated and locked down in Federal depositions, special interrogatories,
4 declarations and trial so that after spending the time and energy NEXT TIME, there will be actual
5 jail terms handed-out, not just disappointment and idiot jurors shaking the hand of Gans, the master
6 manipulator, puppeteer and perjury master. Future publicity will now be required to reach those
7 exact same (and their compatriots) idiot jurors who were mislead by Gans and the Court and
8 confused by Remingtons uneven, improper and likely impossible preparations for irrefutable
9 multiple witnesses against one. Next time, after a few more years of preparations we will
10 absolutely get closer to the TRUTH. The truth is right there near the surface and eventually itll
11 be coaxed out of the Enterprises witnesses mouths.
12 5. Here, it is easiest, the shortest and fastest to say that Gans coaches, unlawfully instructs,
13 writes and wood-sheds the testimony of 100% of his witnesses, as per SOL trial and pre-trial
14 representations of Randalls, Evans, Hillyards and others projected testimony in March to August
15 2016. There was only one qualified exception to that rule in the last 2016 SOL trial, wherein
16 Pulley was relatively straight in most testimony while under oath. Only his NON-SWORN pre-trial
17 work was unethical and wrongfully written by Gans for his signature but not his sworn oath.
18 Specifically, one example of that (of many) is Pulleys primary MAP-chart of the two properties at
19 issue and the survey and Agreed Fence line drawn on them, probably pretty or VERY accurately.
20 Since Pulleys surveyed line has been long conceded as accurate that work was not at issue.
21 6. What WAS WRONG with Pulleys testimony, and is a material misrepresentation drafted by
22 Gans, is the so-called toe-of-the fill line which Gans drew, as a deliberate fraudulent
23 UNDERSTATEMENT of the known proven facts on the ground, as sworn to by plaintiff here, who
24 is the ONLY person on earth who has correctly delineated the edges of the fill in his thousands of
25 hand shovel and mattock excavations all over the fill, at and ON its edges and a few feet or MORE
26 BEYOND the fill where his 18 planting holes encountered ONLY native soils. Remington
27 determined and specifically recalls the soils at or just BEYOND the fill, where plants mostly
28 THRIVE, and therefore HE and he ALONE know where the fill is and is NOT. Mathson, Gans and
Pulley have no idea at all where the fill ends as it is ALL obscured by 2-10 of redwood needles and
59
1 brush and then mostly (99%+) buried under additional sand, organic debris and some eroded dirt at
2 the bottom of the dump.
3 a. Simply put, Gans told Pulley where the fill was and understated it by at least 100% in all 3
4 parameters. In other words, it was twice as long at least twice as wide and at least 3-4 TIMES
5 deeper in 90% of the prescribed dump area. Remington has detailed 3-D charts of all dimensions
6 based on scientific measurements, borings and several THOUSAND hand excavations up to 3
7 deep, plus many other related bits of evidence related to depths and composition.
8 b. What that means is that what Remington swore to at the SOL trial is accurate: Pulleys
9 toe-of-the-fill lines, which were only estimates as he admitted and wrote, and his honesty is
10 noteworthy and commendable there, are WRONG by 4 times linearly and 8-12 times overall as to
11 VOLUME and how much encroaching material RAO and Mathson deposited here in 1998, which
12 materials substantially MOVE down the 50+ degree slopes in every rain, and CHANGE over
13 time accordingly. That variance over time in combination with the reasonable, easy remediability
14 of the sites, mean that we have the classic definition of a continuing nuisance/trespass here, which
15 damages may be SUED for every 3 years until removal of the hazardous materials. THEREFORE,
16 Pulley was tampered with pretrial but did not perjure himself further at the SOL trial. Not all
17 witnesses bend to Gans evil wishes and scripted lies, even for the substantial BRIBES offered of 2-
18 10 times their normal hourly value to society. Paying Joy Mathson, Costa, Skillings and Kishpaugh
19 5-10 times what they are worth to anyone else explains about all you need here as to corruption and
20 the ability to buy virtually ANY testimony. John Mathson has the most to gain or lose here so his
21 testimony is 100% fluid, and ( hypothetically) if Gans needs Remington to be a murderer then John
22 Mathson will be the eye witness and the one who plants the glove or shell casings in Remingtons
23 side yard where Remington allegedly practiced, etc. [This is NOT hyperbolic, as it has become
24 clear to Remington and eventually to ALL, that Gans and the enterprises corruption and
25 desperateness to win matter what it takes, without regard to truth, legality, morality, ethics,
26 committing criminal predicate acts or engaging in LAWLESSNESS, is their over-riding method,
27 which they ruthlessly pursue. All we know for sure now is that RICO enterprise will do something
28 ruthless, dramatic and unlawful, we just dont yet know what thats going to be.

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1 HERE, Gans may well bring-down ALL of his associates as equally culpable for ALL damage
2 if they engaged in even ONE predicate act themselves as the ENTIRE ENTERPRISE are now
3 inextricably linked together, and now they all hang-together, LIE and conspiratorially cover-up in
4 unison or they ALL FALL similarly, if Remington can present this clearly. Also, we need
5 CRIMINAL authorities to help-out here and for Gans, et al to double and triple their State crimes
6 now in a FEDERAL investigation, where the penalties are incalculably HIGHER than in
7 Department 8 where anything appears to go at this point, and California attorney ethics are left
8 at the door, or so it appears to Remington in 2016.
9 7. Additionally, SEVERE felony RICO extortion, bribery, blackmail, intimidation, coercion,
10 and Hobbs ACT FEAR were perpetrated on and engendered in Figas in 2012-13, as previously
11 complained about in depth in the DR140426 complaints. SIMILAR, equally egregious and
12 unexpected extortion (or conceivably the other possibilities to be discovered) was perpetrated onto
13 Remington witness and remediation contractor Wayne Marsh, of Elk River, on November 14, 2015.
14 This episode has been amply complained-of throughout and needs a deposition to determine
15 the exact statements, details and CRIMES committed. SO FAR, both Marsh and Remington have
16 been severely damaged by this latest corrupt act by defendants enterprise, and meanwhile the road-
17 in and REAL excavation of and determination of the horrors buried by RAO remains
18 undetermined. RAO is desperate to keep their crimes secret and what lengths their enforcer
19 Skillings will resort to is a real FEAR and is not yet determined.
20 It is not hyperbolic to allege that ALL of the above acts were inflicted on Figas who was
21 VERY upset about it and he is a VERY tough man ordinarily. Marsh has not yet been spoken to
22 about violating his contract and promises, and will emerge as a larger figure here after his imminent
23 examination and deposition.
24 Figas is emphasized elsewhere in this statement and in addition to the problems presented in
25 201213, new problems arose in 2016 during pretrial hearings and subpoenaing. Figas was
26 threatened, intimidated and scared further in 2016 and although listed as and subpoenaed as a
27 Remington expert and fact remediation witness, he was re-terrified and extorted all over again, and
28 as a result he substantially disappeared during April-June 2016 and inferentially was too
traumatized to face Skillings, Olson, Mathson and the enterprise.
61
1 8. Gans gave the order about Figas directly to his August 2016 trial witness Skillings or
2 possibly acted through his intermediaries Mathson or Kluck. Discovery will determine how orders
3 are transmitted from Gans to SKILLINGS, who in any event is the Luca Brasi (Don Corleone or
4 Godfather-MAFIA, organized crime-type) executioner and obvious psychopath, who has the
5 courage, physical strength, ruthlessness and anger to do the RICO EXECUTIONS, as they
6 become needed. Here, the crime was common extortion and blackmail, centrally but more details
7 are needed from ALL involved and UNDER OATH, because Figas is still afraid to say too much
8 about those traumatic events. John Mathsons mentioned spoliation of evidence, the morning of
9 February 15, 2016 (described below) incriminatingly occurred only a few HOURS before the
10 precisely known date and EXACT HOUR of Remingtons only environmental expert Dr.
11 McEdwards visit and deposition, and also similarly and coincidentally preceded Maje Hoyos
12 deposition a day later. Mathsons corrupt systematic and thorough concealment of the crucial
13 asbestos pipe evidence HAD to have been very carefully and artfully orchestrated and executed
14 by Gans or McBride, the only two people that knew the exact details of the deposition schedule.
15 Similar nasty events occurred in 2012 before Mike Fogets visit when John Mathson intimidated
16 and made Foget and Remington afraid by yelling violently at Foget (and by implication Remington
17 standing 15 feet away), as though he might SHOOT him, or us, at any moment. He yelled: go
18 away get off my property, although we were both at that time at least 30 feet on Remington side
19 of the fence, and Foget was startled and somewhat shaken and fearful that Mathson might violently
20 remove him at gunpoint and/or kill us both, as his strong flash camera in the darkness of a redwood
21 forest aptly simulated.
22 MANY other provable cases of Gans ORDERED witness tampering, extortion, bribing and
23 intimidation exist and can be proven with written discovery and many depositions, some short ones,
24 others NOT.
25 Many other specific examples of witness tampering, including the date, time, effect and
26 damages to Remington and the Burl Tree can be presented, as needed and/or requested at the
27 proper time. They will be explained further under other defendants throughout these several
28 hundred pages of explanations.
9. For example, without limitation:
62
1 A. Gans and Ferriman improperly influenced, extorted and/or BRIBED Jeff Nelson
2 (the boss, CEO over BOTH Remingtons experts Aveggio, and then Foget, after Aveggios
3 premature DEATH) prior to August 2014 (when Remington first learned about it) to eliminate
4 Foget from Remingtons case, severely CRIPPLING it for months. As a result, Nelson is now a
5 prime enterprise named defendant, covered in detail below;
6 B. John Mathsons extensive evidence spoliation from 201216 is covered below in detail
7 under John Mathson. What is clear here however is that Gans manages Mathsons spoliation
8 activities, reviews the 2008-11 photos for what the visual danger spots are (from their defensive
9 point of view) and then has been seen on surveillance video standing at the agreed fence looking
10 out over the dump to see if Mathson has completed his spoliation work properly and seamlessly.
11 Last time Gans was seen surveying Mathsons work was in March 2016.
12 (1) Exactly what was done by Mathson, when, why, and how it fits in with the eight prior
13 years of photography on the sites is now beyond the scope of this section, however the salient
14 incidents relevant here that were known to be ordered by Gans involved John Mathsons' videoed
15 frantic gathering of redwood needles (for 20 minutes) to spread on top of all exposed asbestos pipes
16 on the dumpsite, only a few hours prior to Dr. McEdwards visit on February 15, 2016. That is, Gans
17 knew exactly when McEdwards deposition was (to the minutes, and Mathson knew NOTHING
18 without an order from Gans) and exactly when he would visit Remingtons land for the first and
19 only time. Gans wanted to minimize the visual impact of what he would see then, and they did so,
20 eloquently, and unknown to Remington until about a month later when he reviewed his surveillance
21 videos. Additionally, John Mathson was of course waiting for Dr. McEdwards about an hour before
22 the deposition, and carefully watched and photographed his every movement.
23 (2) For three or four (3-4) years Mathson had been covering, re-burying and largely removing
24 all exposed asbestos pipes from the dump site, so by February 2016 there were only about a dozen
25 left to conceal further, which John Manson did by sprinkling thousands of redwood needles on top
26 of them.
27 (3) Hence, February 15, Presidents Day, Dr. McEdwards visited hurriedly and saw only two of
28 the previous 25 or more asbestos pipes then visible, quite a let down on that account, and also due

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1 to the many other evidence reductions by John Mathson that had already taken place clandestinely,
2 which Remington can and will prove photographically at the next trial.
3 (4) As alluded to above, when the surveillance video was viewed about a month later the whole
4 story was revealed: Gans told Mathson exactly when Dr. McEdwards would visit; Mathson raked
5 up about 40 gallons of redwood needles and branches, on video, and then distributed them by hand
6 on the dump site about 100 feet away, only a few hours before McEdwards visit; and hence
7 Remingtons expert was not awed or impressed by the visual evidence of hazardous materials that
8 had existed for many years, and he was undoubtedly surprised (and likely disappointed) that the
9 real dump today did not correspond with the 2008-11 photos. That may have inferred that
10 Remingtons photos from 2008 were false or doctored, whereas actually the real site today was
11 altered superficially, and all blatant visual contamination clues were minimized and/or eliminated,
12 on Gans orders. Evidence spoliation of this type, removal and substantial and material alteration of
13 a crime scene in that manner is a felony and/or major terminally sanctionable offense under current
14 California law, once a court understands exactly what happened and what the reasons were for
15 same.
16 (5) Additionally, Gans also expected Maje Hoyos to visit prior to her deposition, one day later,
17 so altering the site and sanitizing it killed two birds with one stone, essentially.
18 C. Another important Gans order given that was carried-out by John Mathson was the
19 intimidation of Mike Foget, SHN environmental expert in 2012, while he was visiting
20 Remingtons contaminated site for the first time. Mathson angrily yelled at Foget and Mathson told
21 him to get off my property and Foget was shaken and fearful that maybe Mathson would
22 violently remove him and Remington and/or kill us both. Then Mathson started taking flash
23 pictures in the low light of the redwood forests twilight, which simulated a rifle shot going off with
24 a silencer.
25 D. Additionally, Gans altered his environmental expert Ferrimans 2011-12 testimony and
26 instructed Ferriman to approach SHNs sampling technician and improperly influence him as to
27 John Aveggios integrity and testing results in 2011. The net damage to Remington of that act was
28 extreme. Gans directed Ferriman, and Ferriman apparently directed his own Blue Rock technician
to approach and improperly influence his friend the SHN technician, who got to Mike Foget and in
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1 between the two of them they influenced Jeff Nelson the CEO of SHN to remove Foget from
2 Remingtons case, a catastrophically prejudicial act. Jeff Nelson removed Foget from this case, after
3 Remington had many thousands of dollars of his time and money invested in Foget, and then
4 neglected to inform Remington of that prejudicial move until Remington made inquiries in 2014,
5 after it was too late. Gans had already influenced and prejudiced Nelson against Remington and the
6 exact sequence of facts and conversations will be determined during future depositions. The result
7 of all that for Remington, was that all of Aveggios and Fogets work, was lost as regards to having
8 an authoritative trial witness, and Remington had to start 100% again, very expensively with Dr.
9 McEdwards.
10 Remingtons damages there from being unable to use any of SHNs work which he had spent
11 years developing, was more than $35,000, which consisted of a lot of money directly invested in
12 SHN, but a larger amount of Remington valuable time was involved, at least 3:1 of Remington to
13 SHNs time. Those hundreds of hours of Remingtons time involved planning what was needed to
14 be done and presenting all of SHNs testing and orally sworn work properly in declarations and
15 depositions, for years, etc. That was all complicated, and very damaging to Remington by Jeff
16 Nelson. Since exact damages caused by Nelson very somewhat with each calculation, the final
17 damage estimate will not be calculated until the middle of this trial.
18 E. Gans has perniciously corrupted Morgan Randall to assert that Remington
19 contaminated his OWN plus Mathsons land across the gorge and half way up the next mountain,
20 which is all scientifically impossible. However Gans doesnt do science, presumably had none in
21 college, and he can prevent jurors from doing it also logically, and simply put can charismaticly
22 corrupt and con a jury into believing practically anything, such as that black is white, and
23 virtually any other philosophical fallacy in between. More about the Randall fraud and corrupted
24 testimony is listed below especially under witness tampering.
25 Gans effectively bribed, misrepresented and mischaracterized his defensive case and
26 somehow intimidated Randall into cooperating in his bogus visual nuisance case which was
27 frivolous, a sham and was never intended to be more than an offset to Remingtons valid
28 contamination case.

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1 F. The sham Gans March-May 2016 settlement to extort Farmers Insurance in
2 order to successfully get rid of Roberts help to Remington. Under that agreement between
3 Farmers and Allied insurance companies, Farmers agreed to pay Gans and Mathson the extortive
4 amount of $20,000 in order to remove Roberts from Remingtons case to eliminate their possible
5 exposure and potential attorneys costs of hundreds of thousands of dollars. In other words, they
6 settled away Gans frivolous, strictly retaliatory nuisance case DR 080669 in May 2016, below
7 nuisance value, in order to remove Remingtons attorney, Harvey Roberts and the other major
8 financial drains associated with his consultations with Remington and numerous other expert,
9 deposition and evidentiary costs from this case, which potentially could have cost Farmers
10 Insurance well-into the mid-6 figures of dollars, between May and August 2016 ALONE.
11 Overall, this was no settlement but was more tantamount to extortion as explained, here and
12 elsewhere. Just because a crook has a law degree does not mean that everything he characterizes as
13 a settlement is thereafter above scrutiny, and is honest, legal and beyond criticism under the
14 litigation privilege or CCP 425.16. As explained above and as will be developed further in this
15 case, the Gans/Farmers settlement of a case that Gans could not have won against Harvey
16 Roberts was more of an opportunistic chance to hurt Remingtons contamination case and get rid of
17 his attorney Roberts, then an actual Settlement of anything, and in any event was purely a tactical
18 move to save money by Farmers. DR 080669 was never a serious bona fide lawsuit and was merely
19 a series of fraudulent unsubstantiated, unscientific allegations which could never have prevailed on
20 the merits, but required Gans corrupt, unethical and ridiculous prejudicial advocacy to sustain
21 itself. After we had revealed their fraudulent RICO plans during the severance motion hearings,
22 they obviously realized they had little to no chance against Remington and Roberts after we had
23 determined their strange and shockingly unlawful trial strategy based upon entirely prejudicial and
24 inadmissible evidence.
25 G. Gans has totally corrupted Plotz. Gans chief apprentice, assistant and primary partner
26 in crime is Ryan Plotz. Gans most important evil corruption of a young lawyer was Plotz, who has
27 in effect sold his soul to the devil. Plotz now is a Gans puppet, not unlike John Mathson, and
28 Plotz writes and says whatever Gans requires, then submits his drafts to Gans for additional deceit,
false logic and unethical law citations. The usual result of that collaboration is virtually always
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1 unethical, mostly wrong, prejudicial, mischaracterizes California controlling law, and is usually
2 sloppily, cursorily and generally incompletely researched, and/or in-artfully articulated.
3 1. As explained elsewhere, Plotz is expected to be a major witness against Gans eventually, and
4 he presently is involved in a Consigliore role often, and interacts with most of Gans witnesses as
5 needed, such as Schwartz, Pulley, Gwinn, Ferriman, Mathsons Westgate drug gangs, and the new
6 environmental expert Hillyard. The latter expert is only now employed because inferentially
7 Ferriman, Gwinn and Blue Rock have voluntarily pulled-out of this case, or been fired, and in any
8 event they have lost all their credibility and would have been easy to destroy a trial.
9 2. Therefore, Remington herein alleges that through Plotz, Gans exerts absolute control over all
10 his witnesses and that means Gans controls all the facts. Truth here in these cases has nothing to do
11 with Gans defense as alleged herein and for the last 5-6 years. Gans noticeably went BAD in
12 summer 2011, and has never been straight, ethical or honest since then, for long.
13 H. Peter Esko. This somewhat convoluted story involved Gans corruption of Ferrimans Blue
14 Rock report and then Brisso improperly influencing Melissa Martel and/or bribed her in getting her
15 to designate the unusual, maverick, non-employee, non-consultant, roving expert Esko to strangely
16 intercede in these cases.
17 1. Remington alleges that Esko was craftily assigned by Martel (the LAFCo connection) to
18 exonerate Mathsons dumps hazardous dumpsite issues.
19 In essence, the county improperly determined, based on unscientific, incompetent testing and
20 with no opposition, that Mathsons dump was benign and doing just fine on Mathsons residential
21 Redwooded land. Esko decided it was perfectly legal and therefore not necessary to remove it. At
22 trial Gans has prompted Esko or bribed him to say that if its alright and benign existing on
23 Mathsons land then it would be the same on Remingtons land. THEIR theory: Since it all came
24 from the same place, it is therefore all THE SAME, and there is even less of it on Remingtons land,
25 and therefore what is on Remingtons land (and Mathsons') does not have to be removed, cleaned-
26 up or remediated. Hence there are no problems here, for the environment, the county, the state, the
27 country and what is on Remingtons land does not need to be removed despite our experts
28 determination that it should be removed.

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1 2. The basic fallacy in Eskos and Gans reasoning is that in 1998 defendants carefully sorted
2 all the worse stuff that Mathson did not want under his lawns onto Remingtons property where it
3 was then deeply buried. Therefore, although there is adverse hazardous material on both properties,
4 especially the several thousand yards of gas station remediated hydrocarbon-saturated soils, and
5 related accessories, nevertheless the worst toxins as cited elsewhere, were placed on and remain on
6 Remingtons property because Mathson refused to keep them there on his land in 1998.
7 One of the many conclusions here so far is that Gans has lost all his objectivity and ethics and
8 has become a corrupt player, in these cases, not an objective legal advocate.
9 O. [N. was way back there on page 44] 18 USC 1513, Retaliation against a Witness. So
10 far, ALL of Remingtons planned or used trial witnesses, including himself, have been tampered
11 and/or retaliated against. THEY include: Dr. McEdwards, Figas, Aveggio, Foget, Hoyos, Biassca
12 and Remington, himself.
13 1. Definitions: (b): It is unlawful and can be punished under this section if anyone knowingly
14 engages in any conduct and thereby damages the tangible property of another person or threatens
15 to do so, with intent to retaliate against any person or if anyone affects the attendance of a
16 witness or party at or attending an official proceeding; or (e): for if anyone with the intent to
17 retaliate and takes any action harmful to any person, including interference with the lawful
18 employment or livelihood of any person. Those admonishments apply to varying extents to and
19 with each of the witnesses named above and all the definitions above at A apply specifically to
20 Figas. Discovery and the federal trial world make all of the above completely clear, as it gets kind
21 of overly detailed, complex and lengthy to write out here, now.
22 2. Figas. As complained throughout these documents, obvious violations of (b) & (e) above
23 occurred from Gans through his racketeering mob muscle operatives Skillings, Mathson and
24 Kishpaugh. In this case, the Burl Tree and Remingtons land and property was actually
25 substantially damaged by the above conduct, whereas Figas $100,000+ essentially
26 irreplaceable excavator and related property was threatened with damage, vandalism or
27 complete arson. Those severe threats to his property and livelihood were in addition to the
28 threats and/or blackmail by defendants in threatening to complain to the various state

68
1 regulators and Highway Patrol about Figas purported illicit and/or illegal hauling, dumping
2 and numerous other operating and business violations of his own.
3 Gans retaliatory threats against Figas also clearly violated 1513 (e) because Skillings, et als
4 harmful actions, threats and extortion all related directly to Figas machinery, equipment and
5 trucks, which are Figas lawful employment or livelihood. Figas is Remingtons chief
6 remediation witness and one of his major damages witnesses in all the official proceedings about
7 these matters.
8 Gans, Skillings and Mathson can and should be fined under this title or imprisoned for not
9 more than 10 years, or both.
10 3. Remington. As alleged throughout and in detail below, John Mathson has been retaliating
11 against primary witness Remington since 2012 in an organized manner of extortion, coercion
12 and intimidation as explained throughout. Remington is now complaining criminally about that
13 long-time documented on video and provable, serial felony vandalism and criminal extortion.
14 In any case, all Remingtons testimony is in these official proceedings at all governmental
15 levels and hence Gans has violated 1513 and continues to do so.
16 Gans and Brisso also managed to infect and influence Judge Reinholtsen, and therefore in
17 summer 2016 proceeded to greatly influence all of Remingtons life and testimony. Retaliating
18 against a witness or party (Remington) through the instrument of a judge himself is obviously the
19 worst form of witness influence, retaliation and/or retribution.
20 4. Other witnesses deleteriously influenced by and corruptly retaliated against by Gans.
21 Similarly, but with deference to Rule eight, Gans has adversely influenced all of Remingtons
22 2016 witnesses both directly or through his soldiers and racketeering minions.
23 a) As above, Foget by Mathsons yelling and intimidating threats;
24 b) Maje Hoyos has been bullied, intimidated and retaliated against by all levels of the Health
25 Department which happened because of the RICO enterprises corrupt influence and orders.
26 As much more fully explained below and elsewhere, the Humboldt County Health
27 Department is highly responsive to and substantially under the control of Brisso in at least
28 several ways, including directly through Melissa Martel. However, at least as important is that
Brisso controls the entire County legal bureaucracy and DAs office, whenever that power is
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1 needed, because Brisso has served as acting or consulting County Counsel, often. As a result, he
2 has great influence over most of those staffs especially the highest levels, and whether he hired
3 them and can still fire them is not yet been discovered, but what is clear already is that they greatly
4 fear and/or respect him now, and obviously fear his power, influence and ability to make any
5 reprisals as needed If his will is ever opposed. Maje Hoyos county bureaucratic superiors plus the
6 county legal advisors to her department have so far successfully blocked her trial assistance to
7 Remington in virtually all ways possible, beginning with influencing Judge Reinholtsen to very
8 inexplicably and prejudicially block her testimony regarding any investigations that she did on
9 Remingtons property. Said judge, very strangely allowed her to testify about conditions or work
10 done under different property from Remingtons, but since she did little or nothing there she has
11 been effectively and erroneously barred from the DR 080678 contamination trial.
12 Additionally, RICO defendants Gans, presumably acting through the instrument of Brisso
13 personally, next ordered the county to require high cash payments from Remington to the county
14 upfront, plus also required complex explanations on subpoenas delineating her exact trial role, so
15 that they can then arbitrarily decide whether they (her bureaucratic superiors) will even allow her to
16 be involved in these proceedings at all, especially where a variety of her superiors are implicated
17 here, perhaps even in this RICO enterprise. In other words, the RICO enterprises somehow
18 manipulated the system to where they can in effect give permission for Remingtons
19 contamination witnesses to testify, or more likely they will withhold their permission, leaving
20 Remington devoid of County Health Department expert witnesses;
21 c) Dr. McEdwards has been strongly attacked by Gans in MILs, specifically for only answering
22 the questions that Gans actually asked. Apparently Dr. McEdwards was supposed to answer all of
23 the questions which Gans did not ask, and Judge Reinholtsen appeared to be agreeing with that
24 philosophy during the 2016 pretrial hearings, however he never made a definitive ruling on that
25 specific issue. We made it very clear at, before and during the deposition that since Dr. McEdwards
26 did no independent work himself, he had to rely exclusively on Aveggios testing and testimony,
27 and would therefore obviously have to become entirely familiar with it before trial and than present
28 much of it, at trial. Obviously, Dr. McEdwards would also comment on whether he agreed with
Aveggio 100% or disagree with something, and he made that clear in his deposition. Gans has
70
1 deceitfully put Remington and Dr. McEdwards in the Catch-22 position of not having many of Dr.
2 McEdwards opinions in the record, because most questions about what Dr. McEdwards had been
3 disclosed to testify, were deliberately not asked by Gans. Judge Reinholtsens acquiescence to that
4 type of deceitful trickery, flagrantly intended to diminish and cripple Remingtons expert witnesses
5 was one of the top 30-40 reasons which Remington unsuccessfully attempted to disqualify said
6 Judge. However these and the numerous other issues and perceived errors mostly delineated herein,
7 will be taken up on the first state appeal.
8 Gans cleverly only asked a few substantive questions, got limited answers accordingly and
9 due to McEdwards very brief work here, Gans is now influencing the courts to limit McEdwards
10 testimony, to what he testified to under Gans minimalist questioning.
11 If only 10 questions were asked on very limited topics, how does that justly limit Dr.
12 McEdwards to those topics? We clearly said the Dr. McEdwards would testify about all facts on all
13 topics which Aveggio had previously at a minimum, however Gans is now trying to drastically limit
14 his testimony in addition to attacking his competence and experience. Judge Reinholtsen, over
15 Remingtons strong objections refused to allow McEdwards to do any vitally important independent
16 testing of his own or to do anything independently of John Aveggio which therefore made all
17 Aveggios work the basis of our contamination trial expert testimony, which McEdwards can
18 proficiently advocate, when given the opportunity.
19 P. 18 USC 1952. Bars interstate travel with racketeering or gambling income, BOTH
20 applicable here. All of Gans income in 2016 and the majority from 2014-15, as relates to this case,
21 came from unlawful extortion racketeering income as regulated by this section. The relevant
22 passages from 1951, (a) and (b) are:
23 (a) Whoever in any way obstructs or affects commerce or the movement of any article or
24 commodity commerce by extortion. or who threatens physical violence to any person or
25 property in furtherance of a plan or purpose to do anything in violation of the section shall be fined
26 under this title or imprisoned not more than 20 years, or both.
27 (b) (1) As used in this section: the term Robbery means the unlawful taking or obtaining of a
28 persons personal property against his will including through fear of injury to his person or
property.
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1 (b) (2) The term Extortion means obtaining of property from another, with his consent, induced
2 by wrongful use of actual or threatened force, violence, or fear, under color of official right. All of
3 the definitions above as explained in these documents are pertinent and directly applicable here and
4 Gans is the mastermind of the enterprise that systematically violated all these sections and
5 definitions for several years.
6 The descriptive words and violations of (a) and (b) are clear. Full discovery and a deposition
7 of Gans is now required to determine if he is guilty of 6 counts here or 15, as related to 1951
8 alone, and he is known to have traveled out of state in July 2016 on his non-refundable out-of-state
9 plane ticket, an issue that was raised 4-5 times. That specific example was a salient pretrial
10 scheduling issue however it is suspected that Gans traveled out-of-state in every year between 2012
11 and 2016, for several weeks. Because of Gans' violation of this statute as well as the other 15 16,
12 it would appear that he should be fined and imprisoned under the statute alone.
13 Specifically, during the last week in January 2017 into February there were at least 3
14 hearing resettings due to their Brisso and GANS interstate travel schedule and the 2/3/17
15 hearing was specifically cancelled on that basis to be reset after February 7, 2017. BOTH are
16 traveling on laundered funds from their Remington-related RICO work projects and huge incomes.
17 derived therefrom.
18 Q. Gans violated 18 USC 1956, Money Laundering. Gans is the Godfather in charge of all
19 aspects of this cover-up racket, desperately using whatever means are required, as fully
20 particularized. Violating state and federal laws are not a problem for Gans or his enterprise because
21 hes too to smart to get caught. Many criminals think theyre too smart to get caught.
22 Olson and Mathson are the biggest violators of 1956 and in comparison, Gans is likely
23 technically a more minor figure as to money laundering comparatively speaking.
24 Gans knows that he is paid by Allied and that money comes directly from 40-years of illicit
25 Mathsons premiums, invested at interest, which premiums since 1998 of MORE THAN $150,000
26 are all heavily based on an illicit hazardous materials stockpiling, storage and concealment
27 operation, in the million dollar range, overall. Olson likely had high six-figure profits, but since
28 2012, Gans is believed to have been paid at least $100,000 per year directly based on his illicit
work here, involving extortion, management of vandalism activities and burglary, arson, obstruction
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1 of justice, major serial witness tampering involving more than TEN (10) witnesses and all the other
2 transgressions named herein.
3 Gans is a lawyer fluent in California and federal IRS and financially-related law, and Gans
4 knowingly violated 1956 because he had to know the money he received from Allied casualty,
5 And indirectly from Mathson, Skillings and RAO, etc., involve the financial transaction
6 representing the proceeds of some form of unlawful activity, as per (c) (1), involving the illegal
7 activity cited in (c) (7) (D) & (E) and the other sections cited there. The latter section cited (E) is
8 especially pertinent since it relates to felony violations of 33 USC 1251, relating to water
9 pollution, which is one of the primary criminal violations alleged here.
10 Remington declines to now present 10 additional pages about these known money laundering
11 violations by Gans, but suffice it to say that (a) (1) [Page 68 above only quotes part of the statute] is
12 highly relevant: whoever, knowing that the property involved in a financial transaction represents
13 the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial
14 transaction which in fact involves the proceeds of said specified unlawful activity, is in violation
15 of many serious fining and imprisonment statues as detailed in several pages in the code. Simply
16 put, Gans and other members of his enterprise have concealed and disguised (a) (B) (i) the nature
17 of many of their financial activities involving real estate and have avoided reporting requirements
18 under state and federal law. See also numerous other relevant portions of the 1956 statute
19 including (c) (1): the term knowing that the property involved in a financial transaction represents
20 the proceeds of some form of unlawful activity, which means, as applicable here, the person knew
21 the property involved in the transaction represented proceeds from some form of activity that
22 constitutes a felony or other violations of state or federal law, with numerous detailed
23 qualifications and explanations of all terminology used therein.
24 As discussed herein, Gans has so-far saved Allied huge amounts of money by avoiding a
25 substantial remediation cost and other related damages of at least $350,000, since about 2007.
26 Annual uncompounded interest alone on that amount would be $35,000 times nine years or
27 $315,000, probably more than Allied had paid out here to date on attorney costs. So, Allied is still
28 perhaps ahead on their gambling cover-up, but for certain, Gans is way ahead, having probably

73
1 been paid about $250,000, maybe more by Allied for his extensive unethical and corrupt work on
2 these cases, since 2007.
3 In the context of this case, arguably much of that income was from illegal extortion
4 racketeering, and what percent and how that should be handled at a federal trial is a sophisticated
5 judgment for the District Court judge to determine at the proper time.
6 R. 18 USC 1957 and 31 USC 5340 specifically bar property sales and other purchases
7 using laundered dirty money, and have been violated by Gans.
8 Gans has engaged in monetary transactions, himself involving property derived from
9 specified unlawful activity. That is plain and clear. Once we also prove at trial that said property
10 was worth more than $10,000, then the fines and imprisonments cited in 1957 will be relevant,
11 applicable and govern Gans fate, along with the other violations cited.
12 Gans has assisted the Mathsons with their unlawfully gained increase of usable property of
13 about 1/3 acre, mostly supported illegally by Remingtons land, as complained of in detail in the
14 encroachment and environmental violated statutes, herein.
15 Many others in this criminal enterprise bought property with illegal, laundered funds, which
16 obviously includes Olsen, Skillings, Mathson, Randall, and presumably others here also when
17 discovery is initiated. Kluck, Kishpaugh, Costa and Plotz for example are currently unknown with
18 respect to recent real estate purchases, or not.
19 All known real estate purchases or development involved residential development worth more
20 than $10,000, and considering Rule eight (8), Remington will not now go down the entire statute
21 and all terminology to prove (today) that Gans personally violated 1957, and assisted the
22 Mathsons' and others to do so, directly.
23 Others in the extortion cover-up racket described herein were likely also assisted by real
24 estate specialist Gans but we will wait for further evidence of that in discovery. The above
25 allegations should be a sufficient prima fascia case to put this predicate act at issue, and to allow
26 detailed discovery of all types from Gans especially, as related to all of his real estate transactions
27 since 2008, and the source of funds for same.
28 S. 18 USC 1962 (b) and 1964, additional money laundering violations by Gans, which
injured Remington and the Burl Tree business.
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1 During these lawsuits, Gans acquired many tens of thousands of dollars of illicit racketeering
2 income from the schemes described herein. Inevitably, much of that money was reinvested by Gans
3 small legal partnership (The Mitchell firm), plus buying vehicles, recreational equipment, and toys
4 for his kids (to keep them quiet and happy while Gans schemed against the Burl Tree), office
5 equipment for his home, software, computers, reference materials, trial display equipment and any
6 number of other things that would have all been derived from this illicit racketeering income,
7 alleged. The same use of illegally laundered money applies to many others in the enterprise
8 including Olson, especially, much more so than Gans, however we will discuss Olson and others
9 below.
10 This allegation still needs to be confirmed with extensive discovery to Gans and his Mitchell
11 partnership, and therefore Remington is not now making a specific 18 USC 1962 (b) claim at this
12 moment, but reserves the right to do so in his FAC, or later if future discovered evidence so
13 justifies.
14 Meanwhile, Remington requests civil remedies as prescribed under 1964 against Gans and
15 for the court to order him to desist in further related activities of (a): the same type of endeavor as
16 the enterprise engaged in (to date), which activities all affect the Burl Tree, the owner of
17 Remingtons land at 832 Westgate Drive, an interstate commerce business as we have mentioned,
18 with a total investment of more than $1 million of development on this site, both inside and out,
19 plus nearly that amount in salable inventory, again inside and out.
20 Therefore, The Burl Tree hereby requests the treble damages authorized by (c) plus attorneys
21 fees, As broadly applied to Gans personal involvement in this illegal racketeering, plus the others
22 individual involvement, according to trial proofs.
23 T. 49 USC 5101, et seq14, Gans supervision of the improper safety, permitting and placarding
24 for hauling hazardous wastes, FROM Mathsons property.
25
26
14
27 Note especially 5000a, 5103a- 5108 and 5117 involving proper safety and permitting for
hauling hazardous wastes, such as required placards warning the public of the hazardous load.
28 Gans and Mathson illicitly hand-removed large quantities of asbestos pipe and Chrysotile from
the dump sites, and did not use any proper regulations because they were attempting to avoid
detection by the CHP, and apparently did so according to our investigations.
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1 The purpose of this chapter is to protect (the local community) against the risks to life, and
2 property inherent in the transportation of hazardous materials in intrastate, interstate and foreign
3 commerce.
4 (1) Here, the primary enormous violations occurred around 1998, which could arguably be
5 considered beyond reach due to the SOLs (statutes of limitations). Also, this issue has been well-
6 covered in the state causes of action and in the environmental contamination portion of this federal
7 suit. The Defendants major concealment of their crimes should have tolled all SOLs until 2011-12.
8 However, arguably this could be a RICO predicate act, although unnecessary to avoid dismissal
9 because only two are required, Not 52, or several hundred after discovery begins. In view of the
10 continuing nature of defendants environmental violations, and the fact that new asbestos and
11 HCs are exposed here daily, e.g., today (10-21-16) as new rains begin and erode the sands and
12 redwood needles covering defendants toxins on the dump. Therefore, this issue and this predicate
13 act is mentioned and reserved for Court consideration.
14 (2) Irrespective of any SOL considerations above, which are defendants only hope here or in any
15 of these lawsuits actually, is that John Mathson, Gans, Ferriman, et al, have orchestrated a real time
16 incriminating, criminal evidence removal program, since 2011, but which moved into high gear in
17 2016. The real threat of a judge and jury visit to these toxic contaminated sites apparently gave
18 Gans the brilliant idea of doctoring, altering and cursorily cleaning-up the appearance of the sites
19 surface, and obscuring the large 10 to 20,000 pound objects with vines and debris. Overall, Gans
20 evidence removal program was similar to OJ removing the blood and bodies at the Bundy crime
21 scene before the police arrived, or room sweeping some of the superficial debris from an invisible
22 radioactive spill, for cosmetic purposes only.
23 That illicit, unlawful program has been rampant since December 2015 and fortunately
24 Remington can prove 100% of those allegations with 500-1000 professional (22,000,000 pixel)
25 photos clearly showing the before-and-after of most salient evidence at the dump including
26 extensive site views in every year since 2008.
27 Simply put, Gans, Mathson, Costa, Kishpaugh, Evans, et al have sledge-hammered, dug-up
28 and hand-removed hundreds of pounds of asbestos pipe and other prominent adverse debris that
were prominent in the incriminating 2008 photos. Under Gans management defendants have
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1 visually sanitized the site of many of the major obvious offensive objects, which still remain
2 underground.
3 The contaminated debris is up to 15 feet deep, and probably weighs about 3,000,000 pounds
4 (although we generally use our approximately 2-million pound estimate) so removing 5-600 pounds
5 of asbestos accomplishes nothing very useful, and is merely a pure illegal, racketeering enterprises
6 cover-up.
7 One of defendants false arguments is that they nothing to contaminate the sites here and that
8 Remington mustve done it, our ever we have surveillance video which refutes days self-serving
9 lies.
10 Gans argues: Whats the problem? Remington supposedly wanted the site cleaned-up so
11 were doing just that. Thats a fallacy and the false logic of a criminal, however when they
12 apparently think they can dupe this court or a jury into believing that their removal of a few
13 hundred pounds of asbestos pipe (which visually incriminates them, but does not exonerate them
14 when 1/10th of 1% is removed) affects the 3,000,000 pound dump which averages 8 to 11 feet deep,
15 under a veneer of weeds and redwood needles.
16 Defendants evidence spoliation is purely a superficial prejudicial visual act intended to
17 prejudice the jury, such that we now need sophisticated expert-driven ground penetrating radar,
18 metal detectors and magnetometers to fully delineate the dumps debris volume. Before Gans
19 ordered his superficial surface cleanup, the extent and depth of the dump was clear, but now it is not
20 and expensive new data and tests are required to convince the court and jury of the full volume of
21 this dump. Remington has hand-excavated on it for 10 years and knows exactly what is there,
22 however most of it is now buried, superficially removed and/or otherwise concealed with organic
23 materials.
24 Gans next sophistic argument is that Mathson has only removed evidentiary debris from a
25 zone property, which is a lie. Gans claims that the evidence, which Remington is complaining
26 about, was on Mathsons land, but as Remington just argued above, that was like removing the
27 bodies, gloves and most of the blood from the OJ murder scene, before the police arrived.
28 Eventually, removing all of it has to be done, but removed 10-15 feet deep, OVER 600 cubic
yards, and by excavator, not 2 deep by hand. Doing it now was intentionally devious and corrupt,
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1 premature and one of the purposes of defendants doing it early was to remove it before
2 Remingtons new expert, Dr. McEdwards, could study it, determine its extent, or even decide if
3 there was anything at the site that needed removal at all. John Aveggio, Remingtons initial expert
4 was sufficient to prove this entire case in 2011, but he died prematurely in 2012 and that left only
5 Remington and his photos to prove what was, and still is there. So, Gans has endeavored to cast
6 doubt on the authenticity and accuracy of the photos.
7 Gans ordered violations of 49 USC 5101, et seq, occurred here in 2016 and were, simply
8 put: Defendants have conducted a several year long elaborate evidence removal and spoliation of
9 the hazardous materials dumpsite, all documented on video and hundreds of still photos, and
10 involved hand removal of close to a thousand pounds of asbestos, alone. Mathson then put said
11 hazardous asbestos and related toxic materials into his personal garbage cans, perhaps with the
12 organic garbage, each week, for improper clandestine disposal. Mathson also has a utility trailer and
13 could have hauled some of the toxic debris to the dump separately, but in any event defendants
14 never got any proper placards, used entirely improper protocols and violated 5101 accordingly.
15 All of that and more will be argued and proven at John Mathsons' next deposition and then in
16 Remingtons lengthy declarations, written discovery and at the State and Federal trials.
17 U. Gans also violated 2601, et seq.; 2614-15 through 4642, et seq. (asbestos), and 2619
18 (citizen suits). Violations of many important hazardous materials hauling laws.
19 Additional violations of processing, handling and disposal of many varieties of hazardous
20 wastes were ordered, managed and personally monitored by Gans, as proven by the surveillance
21 video. Gans soldiers, including both Mathsons, Kishpaugh, Randall, Costa, Skillings, et al did the
22 actual physical dirty work, similar to any mafia family or organized extortion racket from the past
23 and films, where everyone is well-paid and happy.
24 The above law violations apply not only to asbestos (see e.g. 2642, et seq.), but to the many
25 other so-far discovered toxic substances found on and within defendants dump, on Remingtons
26 property. Those include, without limitation, asbestos, Lead, benzene (liquid and vapor), PCBs, E.
27 coli and coliform bacteria, silica dust and very concentrated diesel, gasoline and very old degraded
28 motor oil-saturated soils, ETC, as referenced throughout this complaint.

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1 See also above as to the illicit procedures directed and use by Gans to conceal and
2 clandestinely remove and dispose of said toxins, which involve the surveillance video proofs to be
3 used at depositions in future trials related to these crimes.
4 Scores of related laws were of course also broken, from all levels of government. See for
5 example 40 CFR 763, Relating to asbestos, or every single rule, requirement and criminal law has
6 been violated by Gans are under his specific orders. Whatever the RICO godfather, or Humboldt
7 mafia boss orders is instantly executed without questions, like a ventriloquist, puppeteer or
8 controller of a robotic car.
9 As we shall see, prior to Gans involvement here in 2006-2007, and prior to the formation of
10 the present RICO Enterprise and its cover-up operations, there existed a separate short-lived,
11 mostly over 3-10 months in and after 1998, organized criminal operation involving RAO, Skillings,
12 Olson, Randall, the city of Eureka, and the Mathsons.
13 Although historically interesting and unlawful, it was not believed to be an actual RICO
14 extortion operation but something else, which we have been attacking under state environmental
15 laws for years, and here under successive action federal and California statutes and case law.
16 Reiterating, the original 1998-2001 criminal acts which are now being considered by the DA
17 for prosecution, are being systematically obfuscated and covered-up buy a Gans led RICO
18 enterprise, which organically and naturally grew out of this originally garden-variety litigation
19 between 2006-2011, but which defendants lead aggressive litigation team did not commit acts
20 which amounted to obvious actionable criminal predicates until 2012-2016, as explained. Gans has
21 always been grossly unethical, used false premise logic, continuous mischaracterizations,
22 deliberately deceived and confused all judges that have been involved here and violated all known
23 California attorney ethics standards. We got used to that years ago and thought it was normal,
24 condoned Eureka advocacy behavior. But now, especially during 2016, Gans has drastically cross
25 the line over into imprisonment-worthy criminality.
26 V. 42 USC 1983, miscellaneous actionable deprivations of Remingtons rights by Gans.
27 A. Introduction: This statute is very applicable to much of this dispute, but in attempting to
28 comply with Rule Eight (8), Remington more radically condense and simplify his complaints here,

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1 but will explain and expand on the number of specific allegations at subsequent stages as requested
2 by the court, to explain to Gans what charges are actually being made. Gans understands all too
3 well what charges Remington is making here, but since this court and many of the other defendants
4 here do not, Remington still must provide sufficient specificity to overcome the default of
5 dismissal whether that makes the complaint 250 or 500 pages long. Length cannot be the defining
6 constraint where specificity is required for any fraud allegations and most especially for RICO
7 allegations, which are just as real today is in a 1940s black-and-white gangster film.
8 RICO rackets and modern organized crime organizations are still very much alive world-wide,
9 not necessarily as Italian mafia, but where there are humans, weakness, temptation, laziness and the
10 promise of easy or easier money to be made, second-class intellects (e.g. you can read Gans and
11 most of the known enterprise members names in here, in Remingtons opinion), who see the chance
12 to get rich, richer or at least to catch up some to their more talented, smarter, city-located and/or
13 more hard-working contemporaries and competitors, modern small scale RICO enterprises are
14 eminently predictable. Theyre easy to form, and in a small, frontier town like Eureka, they are
15 obviously rather easy to get away with, since they are unexpected and HERE, the cover of a
16 legitimate law firm, with a prior long history of legitimate advocacy, provides almost infinite
17 concealability and incredible legal protection.
18 B. Specific 1983 violations by Gans, et al.:
19 1. Gans, Plotz, Brisso, et al have blocked numerous governmental investigations here,
20 Including those by the County Health Department, the Environmental Healths Hazardous Materials
21 Unit, the California North Coast Regional Waterboard, The Humboldt County Building
22 Department, State Air Quality Control, and the California Toxic Substances Board (among others)
23 all related to defendants obvious overt and dangerous asbestos, zoning and criminal hazardous
24 materials disposal violations, and especially the permanent disposal and storage of said toxins on
25 Remingtons property where defendants buried and then further concealed them.
26 Since 2014, Godfather Gans mostly gave his orders to Plotz (the Consigliore), after
27 consulting with his fellow law partners and before Plotz was employed Paul Brisso played a more
28 important role in the litigation, including dealing with the enterprise and especially with the outside
organizations listed above, including Melissa Martel, et al through their LAFCo connection.
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1 More discovery is needed regarding the above Gans, Brisso, Martel and LAFCo connections,
2 which are very secret, very well guarded and highly sensitive. Discovery will be sought about those
3 connections as well as from other County HAZMAT employees including Carolyn Hawkins, Larry
4 Lancaster and Mark Johnson.
5 2. From about 2008 to 2016 Gans orchestrated numerous serious bogus and frivolous complaints
6 to every known enforcement organization at all levels of every type of government level and body
7 on the north coast. Remingtons complaints of bad faith and intentionally-arranged governmental
8 extortion by about 40 North Coast governmental enforcement agencies, have been made previously
9 in DR 080678, so defendants know exactly what charges are being made here even if this court
10 does not. Many of these complaints were made in 2008 and would be not directly relevant in this
11 RICO action, however as will be specified over the next few years some of those 2008 complaints
12 have persisted and have been consistently reinitiated or better utilized to re-extort Remington
13 during the last four years. See Volume III for pages 11-12 of Remingtons contamination trial
14 exhibits which portray that complaint in colorful chart and photographic form. Said charts and
15 Color Photos were not yet used during the 2016 state contamination trial proceedings, summarize
16 the specific agencies with a one sentence explanation of what the frivolous defendants allegations
17 were, and are expected to be used as trial exhibits here.
18 The Mathsons participated in these schemes but only as Gans microphone, agents,
19 representatives and Enterprise soldiers. The Mathsons never think for themselves and although
20 Remington was too stupid to initially see Gans individual involvement in all crimes, which have
21 occurred here over the last 10 years, or to blame Gans personally early on, it is now clear. Earlier,
22 Gans attorney-client privilege, charisma, self righteous attitude, his work product privilege and
23 officer of the court protections, caused confusion to Remington, but most of that is unprotected
24 under RICO, and has been clarified, after many additional months of studying the relevant law.
25 That is one of the fundamental purposes of RICO, to attack and punish the Godfather, whether hes a
26 California attorney or not. Under many laws the racketeering Enterprises leader would go free and
27 only the soldiers and minions who make the phone calls and collect the overdue debts or bully the
28 neighborhood would be convicted. Now, however, RICO enables the conviction of the person, even

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1 if he is a California attorney, who controls the enterprise, plans the illicit policy and crimes and who
2 administers and orders the punishments, not just the soldier that pulls the trigger.
3 Here, as explained throughout, as Remington kept instinctively fighting for many years here,
4 Gans kept applying endless and increasing pain, torture, huge monetary and time costs, plus
5 physical suffering, including disease. John Mathson, Skillings, Randall and Kishpaugh were usually
6 the instruments for Gans, who absolutely controlled Mathsons and the others, as required. Plenty of
7 cash, charisma, the highest level of expert sales abilities and loyalty to the poor Mathsons were
8 about all that Gans needed. It is now clear that until Remington gives all his resistance up, bends-
9 over for Gans and admits TOTAL defeat, Gans will continue his endless torture, which therefore
10 continues unabated today. However, now and into 2017, at least we can now directly attack the nest
11 or insidious, deadly hive where the queen or overriding evil Lord or devil resides.
12 Therefore, the 40+ governmental authorities that harassed Remington mercilessly during
13 2012-2016 or earlier, are an important predicate act, which would take over 100 pages and may take
14 three (3) days of trial testimony to fully explain.
15 3. File Room Spy. As partially explained above in other categories, the Humboldt Superior Court
16 file room felonious saboteur, mole and/or Gans paid spy has cause Remington enormous problems
17 over many years including the last four. That spy has been known about and complained about
18 for years, and has been especially onerous and in violation of many felony state and federal laws in
19 this 2012-16. Simply put, and as also explained elsewhere, about 30% of Remingtons filed court
20 documents, averaging several hundred pages each, and up to 2000 pages, almost never get filed or
21 distributed properly to the intended court room, whether it was Department 2, 8 or now Department
22 6 in 2017, and even today these problems persist. Periodically Remingtons name is removed from
23 the court service list and he rarely receives important court orders or documents in a normal or
24 timely fashion. For example, today, December 7, 2016, Remington has been waiting three weeks
25 for a copy of todays court minutes that the court directed was to be sent to plaintiff back on
26 November 15, 2016. Nothing has been received despite phone calls about the matter which were
27 not returned. Therefore, today Remington has no idea what judge has been assigned to DR080678
28 that has only been going on for eight years now. Also in that not received court order, Remington

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1 would hope and expect to hear about which judge now administers each of his State cases, and why
2 that is.
3 A. Over the years, many other specific instances have been cited, or could be cited again, in
4 writing, to the various state court executives and file room managers since 2008. Sometimes
5 progress has been made for a year or two, but in 2016, the problem still exists today just as bad as
6 ever. During the hundred+ days of 2016 pretrial hearings, when Remington could directly file his
7 documents with the Department 8 court by just handing them to the clerk for file stamping,
8 everything worked perfectly, without the other intermediaries, and for 4 months.
9 B. The worst problem over the last several years was that someone split-up Remingtons
10 documents, removing top clips, confusing properly Judicially Noticed documents from federal
11 court with current state documents, and in that case assuming that Remington had filed the
12 federal state-court judicially noticed documents in the wrong court, and therefore return them to
13 Remington, or worse: call him to pick them up himself, and in any case the intended judge never
14 saw the in a timely fashion if at all. Numerous related or similar problems occurred over the years,
15 which often also involved breaking-up and in affect, even shuffling Remingtons filed documents,
16 rendering them confusing, useless and even incriminating to Remington as final, total (but
17 FALSE) proof of Remingtons total incompetence and ineptness, as Gans has been arguing.
18 All of this document confusion obviously helped accomplish Gans continuous objectives of
19 getting Remingtons cases dismissed on technical grounds, the facts of which are again rather
20 obvious: Without Remingtons proper Oppositions, lengthy Supporting Declarations, Motion
21 supporting Memorandum of Points and Authorities, or Replies, Remington could not express his
22 positions to the state court, which is obviously prejudicial to Remington, violates Remingtons civil
23 rights and it is also criminal by whoever is doing it.
24 C. What offense, by an attorney or Superior Court employee, could be more outrageous and
25 criminal than deliberately removing a pro per litigants opposition, or removing half of it, rendering
26 it all unintelligible, impossible for a court to reasonably understand and consider it? So, in any case
27 Gans motions often had no proper timely opposition, and they may have been granted on that basis.
28 Other than that, Gans thinks these crimes against Remington are humorous and no big deal.
Whenever Remington complains about this to the judge, Gans always kind of discreetly smirks or
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1 nervously laughs a little about it, and then happily pays his courthouse confederate, no doubt.
2 Judd Reinholtsen listens with feigned interest, but has never appeared to get even remotely angry
3 about it or made any suggestion about doing something to stop it. Serial document tampering in
4 Humboldt Superior Court is a serious imprisonable felony and Remington is going to urge that the
5 DA start its investigation right there next door, in the Humboldt County courthouse, but due to
6 Brissos above-described influences, Remington expects nothing.
7 D. The pre-imminent example of the above felony document tampering of Remingtons filed
8 documents in the courthouse occurred in December 2014, when Remingtons 1500-page collateral
9 estoppel summary judgment opposition documents, including appendices and judicially noticed
10 federal documents, were not timely distributed to Judge Miles. And then later, after her preemptive
11 disqualification by Gans, they were not properly sent to Judge Reinholtsen, but instead they were
12 confusingly unclipped, separated, shuffled and then scattered around the file room randomly, and
13 some were resent to Judge Watson. But Judge Watson had needed a full set as he was
14 simultaneously adjudicating an obviously frivolous, vexatious and extortive vexatious litigant
15 Motion filed by Gans against Remington, which Judge Watson quickly DENIED. It Took
16 Remington about two months to get this somewhat sorted-out with the court executives, using
17 indexes, special searches, several letters describing all of this corrupt, aberrant and frequent
18 outrageous file room errors and inactions, plus hearing discussion remarks with two judges.
19 Today, Remington still has reasonable doubts that all intended documents got properly to either
20 Judge Watson or Judge Reinholtsen, however apparently they gave Remington the benefit of the
21 doubt, because he WON both motions, which involved these scattered, disorganized and somewhat
22 resulting unintelligible oppositions.
23 E. Judge Reinholtsen. Remington attempted to disqualify Judge Reinholtsen preemptively and
24 then for cause in September 2016, a process which has still not yet been finally completed or
25 understood15. Judge Reinholtsen appears to have accepted disqualification for cause in DR140426
26 15
Written in fall 2016, even in March 2017 this situation has not been resolved. A hearing was
27 held on November 15, 2016 which Remington did not know about and Judge Reinholtsens
written instructions were to send Remington the minutes of that hearing regarding Remingtons
28 two cases DR080678 and DR140426. That was never done, despite Remingtons requests, and
even now we dont really know what judge is hearing which case or why. February 17, 2017,
Judge Reinholtsen did hear DR 080678 apparently with the intention of ending it enforcing an
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1 after appearing to oppose it by Declaration, however as alluded to above, whether he is still our
2 judge in DR080678 after serving as judge for all purposes for about eight years, is still in doubt,
3 because as complained of above, the court clerks have still not explained what they did, almost a
4 month later, as they had promised that they would, on November 15, 2016, see FN #15 for more.
5 F. Gans vandalisms. From 2012-2016 Gans planned, organized, ordered, managed and
6 applauded at least 115 major documented acts of vandalism of plaintiffs fences, gardens, residential
7 windows, stoner, ornamentation, gardens, irrigation lines, pumps, paths, mill equipment, patent
8 pending devices, burl and several vehicles on the 832 Westgate site.
9 Probably Gans used his soldiers, puppets and especially his ventriloquists dummy John
10 Mathson and his Westgate gang of old drunken drug-users, but since Gans himself has been seen
11 frequently on video, e.g. March 18, 2016 at 8:12-8:45 AM, it could also be inferred that Gans has
12 personally vandalized Remingtons property out of spite, just to hurt Remington further whenever
13 he visits the sites. Gans always comes very early in the morning at least 4 to 5 hours before
14 Remington is known to ever be there. Defendants know that all too well and Gans never comes near
15 the place when Remington might conceivably be there to see him.
16 Meanwhile, the dangerous animals which defendants allowed to lurk and dart all over
17 Remingtons land, 24-7, have effectively terrorized Remingtons entire family and frightened most
18 of them away permanently, especially his granddaughters, between ages 3-7 during this period and
19 his wife, Suzanne, now too traumatized to ever go to Westgate, as described.
20 Gans law degree is not a halo, angels wings, or an Emperors crown, but merely covers-up
21 his Devils face, ears, destructive ideas and criminal racketeering enterprises actions.
22 Gans intention was and is to drive Remington completely from this neighborhood, force
23 Remington to sell the Burl Trees entire estate cheaply (likely to some member of their syndicate),
24 and contaminated, as their single most important objective has long been proven to be and
25 emphasized that defendants will not spend one dime on cleaning-up Remingtons land. Quite
26 appeal, although as discussed elsewhere the clearly proper procedure next is to conduct a Mangini
27 II jury trial over the issue of whether Remington has properly alleged a continuing nuisance and
trespass or not. It would appear that Judge Wilson is now the arbiter of DR140426, however that
28 has never been written or transmitted to Remington, possibly because of the interception of
communications by Gans file room saboteur, or perhaps because said saboteur removed
Remingtons name from the court service list, once again, as occurs every couple of years.
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1 possibly the enterprise itself wants to buy the place, as Mathsons daughter would like to live closer
2 to her parents, but only if they can get Remingtons land for about ten (10) cents on the dollar as
3 they intend. But in any case, the facts are that defendants never did, do not want to, and will never
4 voluntarily pay for a cleanup, and it will take extreme court pressure and orders to get any kind of
5 fair or just response from Gans, the Mathsons and defendants enterprise.
6 G. Gans coercive and extortive petition. Gans and the Mathsons circulated a petition around
7 the neighborhood during 2008 to attempt to the Humboldt County planning commission to kick the
8 Remingtons out of the neighborhood because they didnt like the appearance of his yard, storage of
9 redwood burls behind a solid gigantic hedge, the construction of his world-class enormous gardens,
10 or his large residence under construction. Therefore, beginning in 2008, and continuing with his
11 general orders since then extending from 2012-16, Gans has promoted a class war of sorts here to
12 try and turn the entire neighborhood against Remington. His intention is to drive out all higher
13 class uses from this lower middle class ordinary union-card type, trailer trash and automotive
14 repair yard (in each driveway, especially Mathsons and Kishpaughs across the street from the
15 Mathsons) culture here. This neighborhood is kind of like an environmental friendly, anti-global
16 warming, and fancy, expensive European architecture and gardens-LOVING, classical music and
17 college-grad school educated and/or save the redwoods culture versus defendants dumpy blue
18 collar, high school drop-out, old, disabled and mostly laid- off Pulp Mill maintenance workers
19 union, drag-racing mechanics, marijuana use and culture, ENVY and wanna-be upwardly mobile
20 class, in effect. A cultural battle seems to exist here now, which Mathsons collusive, perjurious
21 friends and co-conspirators well-coached and totally scripted by Gans have been winning recently
22 with their August 2016 SOL trial jury of their peers, in effect, but unfortunately NOT
23 Remingtons peers. None of the above petition and fomenting of class warfare is illegal under either
24 state or federal law, so as merely mentioned as very important background to clarify and reveal
25 what defendants REAL intentions are here, which are secret and they will never reveal them even
26 under oath.
27 None of that above very petty and bigoted class-warfare crap interests or motivates
28 Remington at all, but the Gans and Mathsons' led Enterprise forces and their faction of probably
about 30% of his immediate neighbors, also do not like someone different from themselves living
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1 amongst them. Many on this street hate differences, and Remington is perceived as somewhat
2 different from the Mathson-Kishpaugh faction, for the reasons discussed in the above paragraph,
3 which can probably be condensed into being based largely upon his large uncompleted, highly
4 ornamented, very fancy, NON- California ranch, and potentially nearly palatial, but as yet
5 uncompleted estate and massive rose and deciduous tree gardens, with over 15,000 rare, non-native
6 and irrigated species.
7 H. Gans and defendants damaged Farmers Insurance by at least $20,000 recently, and by
8 association Remington, who now pays increased premiums for life, and also very prejudicially
9 lost his allied attorney, who helped Remington oppose the enterprise for four years and in
10 battling Gans and the Mitchell firm before that.
11 By employing the long intimidation, extortion and intentionally fraudulent sales process fully
12 described herein, Gans eventually convinced Farmers attorney Harvey Roberts, over many years,
13 that they would possibly prevail against Remington on their fabricated, frivolous allegations in
14 DR080669 and that Farmers should therefore buy their way out of that lawsuit, and not pay Harvey
15 to sit by Remington in court waiting for the trials, which in this case lasted 100 days, just to get to
16 one small part of those trials. Gans had developed a complex and entirely frivolous offensive
17 lawsuit against Remington, DR 080669, ostensibly for visual nuisance and further alleging that
18 Remington had constructed an ugly fence and had also contaminated both properties in a
19 scientifically impossible manner, among other bogus and retaliatory allegations. But, Gans made
20 his case serious and believable and rather easily duped farmers and Roberts into opting out of
21 defending Remington in that case, because it was potentially very expensive and time-consuming.
22 That was clearly true and therefore it was A smart decision for Farmers to opt out, no doubt.
23 Nevertheless overall Gans arguably outsmarted Farmers adjustor Mazie Klein and
24 Remington by extorting them for $20,000, which apparently went to John Mathson for his crucial
25 role as Gans chief vandal and soldier. That extortion of Farmers gravely damaged Remington and
26 his forces and now requires Remington to stand against this entire enterprise alone, whereas before
27 Harvey and Farmers paying some of the joint experts, such as Tidwell, was very helpful.
28 That $20,000 Farmers payment was like a protection payment to Gans enterprise to protect
them from the several hundred thousand dollars which the enterprise was potentially making them
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1 liable for by way of legal fees, costs and potential judgments. If Gans had any legitimate, honest
2 counterclaim and/or fair defense or legitimate response to Remingtons contamination claims, Gans
3 frivolous case would not have existed at all to be settled away. Farmers may be able to afford it,
4 but that does not make it right and for Remington that is just another predicate act perpetrated by this
5 RICO conspiracy. Said above $20,000 artful scheme and device by Gans served them very well by:
6 1) Getting $20,000 to the Mathsons for their corrupt vandalistic and extortive services and to show
7 that Gans was actually benefiting them; 2) Getting Remingtons primary assistant, trial attorney and
8 legal authority out of the case, which left Remington semi-defenseless in a jury trial, which Gans
9 assumed would be fatal for Remington, but was not; 3) Saving themselves 2-3 weeks of trial
10 expenses in a case which they would have most likely lost and possibly even have incurred punitive
11 damages, especially if the two cases had remain consolidated. So, a huge win- win for Gans!
12 However, Farmers Insurance and likely Harvey Roberts also WON big, and they saved
13 at least $150,000 and possibly as much as $500,000, merely by virtue of missing at least 100
14 consecutive pretrial hearing days, possible adverse verdicts, plus potentially another hundred
15 consecutive days of pretrial and trial expenses, which still would be going-on again this spring,
16 into a contamination trial, which has not yet been held.
17 In other words, Gans, Allied insurance, Farmers and Roberts all WON very big and
18 potentially and most likely save themselves ALL a lot of money. The only obvious loser here so
19 far would be Remington, who lost the assistance of his trial counsel and now has to pay for
20 numerous expert witnesses. On the other hand, with Gans suborning of perjury among all of his trial
21 witnesses, it cannot be fully dismissed that the enterprise might conceivably have defeated
22 Remington in DR 080669, even with Harvey Roberts conducting the trial, so we dont really know
23 now, and can never know the final outcome of all this until its all 100% over.
Today, although it is somewhat complicated and subjective, Remington would consider this to
24
be an additional damage caused by Gans tricky and extortive scheme to adeptly discharge Roberts
25
and farmers from assisting Remington with his cases at trial, and overall there intention was clearly
26
to make Remington too afraid to continue with his litigation, which again is exactly and 100%
27
consistent with and in conformance with the Gans RICO protection racketeering enterprises stated
28 purposes and objectives.
I. Generally, Remingtons 1983 claim involves:

88
1. Defendants continuing deprivation of Remingtons contractually created property ownership
1
and boundary rights and abrogation of his right to live happily and free of nuisances and
2
defendants trespasses;
3
2. Defendants substantive deprivation of Remingtons procedural due process rights by the
4
activities alleged herein. Deprivation is caused many ways including removing default healthy air
5 and waters and replacing with diseased vapors and bacterial and other infectious run-offs which
6 cause grave illnesses;
7 3. The deprivation of Remingtons healthy environment, causing sickness and failing bodily
8 integrity as Remington has been almost continuously ill since 2013, which was clearly caused
9 initially by toxic bacterial infections and then continued aggravation by inhaled friable asbestos, all
10 clearly emanating from Mathsons illegal septic systems and the defendants dumped materials on
Remingtons property. Those illnesses and ailments were also aggravated by the general stress-
11
induced by defendants criminal harassments, malicious prosecutions, violated stipulations and
12
general attempts to torture Remington and to make his life as difficult as possible and hopefully to
13
quickly end all this by just killing him, as defendants have frequently threatened and alluded to
14
doing.
15 4. Gans and defendants toxins are believed to be affecting the up-wind neighborhood,
16 according to trial proofs and future investigations when time permits. Shortly, Remington will
17 interview in-depth the 50 or so nearby and immediately upwind residents to see if there are any, and
18 HOW MANY respiratory, infectious illnesses, chemical poisonings, asbestosis symptoms or
19 premature deaths are actually rampant up there, as would be inferred.
20 J. The enterprises stenographer, Marcie Conn. Finally, relevant here, and also under 18
21 USC 1503, Obstruction of Justice is the blatant misuse of Conns erroneous and faulty 2010
22 deposition of Bruce Remington which was complained of vociferously at the August 2016 SOL
23 trial and elsewhere.
24 Remington never agreed to its validity in 2010, refused to sign it in 2010 under any
25 circumstances, and determined that there were thousands of errors and MANY too MANY to make
26 accurate corrections, and therefore through his attorney Harvey Roberts, Remington filed a
27 contemporary written objection to Gans and Conn, to either retake the deposition or throw away the
28 defective one that they had done, which certainly appeared to be intentionally BAD and justly

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1 unusable, except for Gans to script and write his own Remington testimony at all of the hundreds of
2 blanks and untranscribed portions of Remingtons testimony, depicted as three dots.
3 Defendants entirely ignored Roberts and Remingtons objections and in August 2016
4 proceeded to use that deposition detrimentally against Remington as a witness, anyway, despite its
5 being clearly worthless and unusable on its uncorrectable face. Remington objected to that use and
6 cited the relevant California controlling authorities in CCP 2025.510.570 and Rule 30.
7 Remington further demanded that Gans certify, under oath, the deposition transcript he was
8 using, as accurately reflecting the questions he asked and the answers that Remington had given,
9 but Gans refused to do that, as did Conn, when she had been asked. The court compounded its
10 numerous prior errors by committing further trial error on this issue, and refused to prohibit Gans
11 from using that deposition, or even giving the jury some sort of limiting instruction based on the
12 obvious facts of looking at that unintelligible deposition. Thus Gans proceeded to ask Remington
13 several questions from it, however since Gans well-knew that Remingtons objections were valid,
14 he stopped using it very quickly, before a major prejudicial appellate record could be made, after
15 getting some good early mileage from it.
16 Predicate act? Probably not, however this is just another of the hundreds of unethical, illicit
17 and unjust acts and occurrences that Gans and the enterprise did in support of their corrupt
18 racketeering enterprise. Remington will attempt to structure this incident plus several hundred
19 similar ones into questions for Gans, Plotz and the other attorneys in particular to answer under oath
20 with regard to the facts, implications, inferences and corrupt intent, or lack thereof. Since
21 Remingtons special interrogatories and requests for admissions will end pretty much before they
22 even begin, Remington will therefore focus heavily on lengthy detailed and substantive deposition
23 questions. Said depositions will undoubtably have to be frequently adjourned to get court
24 permission or denial to ask the thousand or more questions which Gans, et al, will object to and
25 refuse to answer as being too incriminating. Thus, an imminent Discovery Circus is anticipated.
26 As explainedIn considerable detail BELOW, any illegal corrupt mafia or racketeering
27 enterprise does not do 100% illegal acts, but mixes-in and some perfectly legitimate ones, perhaps
28 like stopping at McDonalds for lunch, amongst the many unethical and illegitimate acts which are
BAD and reprehensible but illegal, necessarily. Even Hitler, or any mass-murder, such as
90
1 Eichmann say, occasionally gets involved in legal or legitimate acts or activities. If the
2 aforementioned go to a concert or stop at a market to buy fruit, is that a corrupt racketeering act or
3 crime? Clearly not. Even the worst criminal on earth does not conduct 100% criminal activity, and
4 it would be according to common sense have to be interspersed with other ordinary non-criminal
5 activity. Further, is going to the bathroom criminal activity? Probably not.
6 W. Gans, Mathson and their enterprise violated 42 USC 102 by using, dealing-in
7 and/or otherwise selling controlled substances.
8 The odors wafting over from Mathsons land are quite unmistakable, even to someone that
9 chokes at the smell of marijuana, hashish or the prevalent wood smoke, settling over from
10 Mathsons yard for about 10 months out of the year, when there is zero wind, which is often. Just as
11 some of the hasty clandestine activity over there is suspicious, wherein people pull-up in their
12 cars going into Mathsons (and Kishpaughs, as complained of elsewhere) house quickly, seriously
13 in a very businesslike, hasty, furtive, guilty-looking and unfriendly manner, and then emerge
14 quickly and drive-off with pretty much the same severe looks on their faces. What all that means is
15 unclear at present, however Remington presently has several local (and/or ex-local) witnesses that
16 pay attention to these kinds of things and know the odor of marijuana, amphetamines, etc. THEY
17 have alleged to Remington what they think, or know, is going on there, so we will be investigating
18 those allegations further, corroborating them with our extensive surveillance video from many
19 cameras, looking for common faces, etc., and then discovering what Mathsons', Gans and other
20 defendants excuses and flat denials are for the aberrant and odd-behavior exhibited on and off
21 camera, over MANY years.
X. Since the attorney-client relationship is analogous to that of an agent-principal, the
22
general rule that knowledge of the agent is constructive knowledge of the principal is also
23
applicable to the attorney-client context. See Hunter v. Watson (1859) 12 Cal. 363; Mossman v.
24
Superior Court (1st Dist. 1972) 22 Cal. App.3d 706. As such the attorneys negligence can be
25
imputed to the client. See Sauer v. Superior Court (4th (Dist. 1987) 195 Cal. App.3d 213. Since the
26
rule rests on the assumption that lawyers generally comply with their duty to communicate relevant
27
information to their clients, the fact that the lawyer did not communicate such information to the
28
client is not a defense. Hence, a client is held to constructively know what his or her attorney

91
actually knows and should communicate with him or her. See Lazzarevich v. Lazzarevich (1952) 39
1
Cal.2d 48, (cites).
2
THEREFORE, BOTH Gans and John Mathson are implicated and guilty here, as per the
3
surveillance videos, so BOTH should pay, although generally the higher-up masterminding
4
criminal intelligence is the more highly sought target of the authorities.
5 Also, DR 2-109 prohibits advocating a position merely for the purpose of harassing or
6 maliciously injuring a person (even a PRO PER), while CRPC 3-200 prohibits advocating a
7 position without probable cause and for the purpose of harassing or maliciously injuring a person.
8 The wording of CRPC 3-200 seems to indicate that it might be possible to maintain a position
9 which by happenstance harasses and maliciously injures, as long as probable cause for the position
10 exists. However, Civ. Proc. Code 128.5, (code/CA STAT.HTM #128.5) authorizes the imposition
of sanctions on lawyers for bad faith tactics that are frivolous, and defines frivolous to mean
11
totally and completely without merit or for the sole purpose of harassing an opposing party. [See
12
3.1:200 CA NARR 3.HTM #3.1:200] Non Meritorious Assertions in Litigation, infra; 3.1:300 (CA
13
NARR 3.HTM #3.1:300) Judicial Sanctions for abusive Litigation Practice (Especially Rule 11),
14
infra]. Although CCP 128.7 supersedes Civ. Proc. Code 128.5 as to actions filed on or after Jan.
15 1, 1995, barring any legislative action, the law will revert back to the requirements of Civ. Proc.
16 Code 128.5 on Jan. 1, 1999.... [CA Legal Ethics].
17 A basic tenet set-forth in California law governing the conduct of lawyers is that frivolous
18 legal positions without merit are unacceptable. For example, under B & PC 6068 (c) a lawyer
19 has a duty to bring only legal or just claims or defenses (except in the defense of criminal
20 actions). This concept is reinforced by CRPC 3-200, which prohibits taking a legal position which
the lawyer knows or should know is (1) without probable cause and for the purpose of harassing or
21
maliciously injuring any person or (2) against the law (i.e. frivolous). Unless supported by a
22
good faith argument for a change in the law. Thus, all attorneys are held to the reasonable
23
attorney standard of conduct when it comes to taking a legal position.
24
Remington paid a lot of attention to the California ethics codes back several years ago, but
25 now understands that they are silly, not really enforced in the modern unethical age where many
26 people are devious and/or corrupt, including court personnel and many attorneys. It now would
27 appear that in order to bring a crooked attorney to justice it takes egregious and provable criminal
28 behavior involving numerous crimes over many years. Remington believes that we now have that
here and so he no longer focuses on ethical violations and disbarment but is made the assumption
92
that the latter will follow when a court awards prison terms to some of the participants here. At that
1
time, disbarment should be rather automatic and perfunctory, and that is the present focus in 2017,
2
whereas the 128.7 and other somewhat naive ethical discussions here were mostly drafted around
3
2014, before Remington appreciated the fact that he was surrounded by ruthless criminals, even
4
then.
5 Y.16 OTHER, numerous, miscellaneous Gans ethical shortcomings, deceptions,
6 deliberate FRAUDS ON REMINGTON AND THREE (3) COURTS, intentional material
7 misstatements, LIES, gross legal inconsistencies, damaging misrepresentations and
8 oppressive, deceitful Gans acts, ETC only briefly condensed here [after page 532 herein], but
9 sufficient for Gans to RESPOND to each and every one with a sworn DENIAL, if he dared,
10 which he doesnt, so hell ignore ALL of these 100%, as he did in the CCP 128.7 ethics hearings
in 2014. Recall, we learned all too well at least six years ago that Gans always ignores direct
11
attacks on him by a pro per litigant, and MOST California JUDGES acquiesce to the following
12
principle: If Gans does not respond to a factual attack or important issue or point made by
13
Remington, or likely by ANY pro per, THEN IT DOESNT EXIST!
14
In other words, in court hearings before Judge Reinholtsen for instance, it does not matter
15
what Remington alleges or how much proof he offers, because it is extremely rare for said court to
16
even look over at Gans after say a 20-minute attack, and say Mr. Gans?. Gans sometimes says
17 something or not, but never very much, and if he does not act guilty or anxious than the court
18 generally just moves-on appearing to infer that Remington is out of line, perhaps wrong or more
19 likely just crazy. Other times, said court is not even asked Gans to respond and just retorts
20 angrily at Remington: I dont want to hear that Mr. Remington, or similar, which infers to
21 Remington at least that Judge Reinholtsens former Mitchell firm law partners are far more
believable in their silent non-answers, than literally anything that Remington could allege that they
22
had done wrong. In other words, in Humboldt County, Gans, Brisso and the Mitchell firm can
23
literally do no wrong, which has again literally forced Remington to seek justice in San
24
Francisco federal court.
25
Judges that condone that long-established, successful Gans strategy and overall policy make
26
it very difficult for Remington to gain traction in this state court or to PREVAIL on any significant
27
16
28 See page 532+ for this 20 page insert which is put near end to avoid hundreds more
formatting and indexing errors, caused by the length of time spent drafting this Rico
Statement.
93
ethical or scientific issue. Obviously, if those facts were accurate and true, it is obvious that
1
Remington cannot obtain justice against the Mitchell firm in Humboldt County Superior Court.
2
3 A Related 20-page insert is now inserted at page 685+.
4 [It would have more appropriately been placed here, however the programs that Remington uses
5 crashes too often to make major inserts into a 738 page document. As it is, saving every 5-10 words
6 during editing is very onerous, but losing those 10 words is even more annoying].
7 2B. LINDA LAWRENCE, ALLIED CASUALTY INSURANCE account manager, chief
8 claims adjuster for the Mathson litigation and sole financier of Gans racketeering enterprise.
9 She is herein sued as an individual, not as an insurance company, for the reasons explained.
1. Introduction.
10
Ms. Lawrence allegedly operates out of their Western regional office at 2251 Harvard St.,
11
Suite 200, Sacramento, CA 95815-2251 Harvard St., Suite 200, Sacramento, CA 95815.
12
Ms. Lawrence has been involved here for many years and she is believed to be the
13
representative that Remington physically met at a 2010 mediation. She was again involved at a
14
settlement conference in 2012, but appeared there by phone. Lawrence sees all of Gans corrupt
15 Enterprises Time records, Costs and Summaries of what work was done by each person, and is
16 believed to be intimately involved in all every-day aspects of Gans illegal enterprise. In 2010, she
17 seemed to think all this was quite humorous and that crushing Remington like an insect would be
18 simple and enjoyable. She is very young-looking, smiles a lot butIs rather clearly not a mere
19 attractive bimbo, and in fact she could be the real Balls behind Gans, and overall is likely the
20 overall Evil Emperor behind all the criminal racketing and racketeering operations, its planning
and also its FINANCING, the single most important corrupt and illicit activity which confronts
21
Remington. Maybe she has 2-3 immediate bosses who are familiar with all details of her work and
22
all aspects of Gans and Mathsons racketeering enterprise, however preliminarily to discovery, that
23
seems very unlikely. In all probability, no one closely supervises her and thus shes been able to
24
run rampant in finance this RICO racket without obstruction or complaint for 10 years now,
25 including its precursor and more legitimate roots.
26 We dont know absolutely for sure who the correct Gans-Allied account manager is today but
27 Lawrence is now being sued according to our best information, which is to use Karissa Lowry of
28 2710 Gateway Oaks Dr., Suite 150 and, Sacramento, California, 95833 as per the current Internet
designated information. Lowry is listed as the agent for service of process. If we called-up Gans
94
or McBride for information about this, they would obviously refuse and then hang-up on
1
Remington, similarly to if Remington called up the Godfather to ask which businesses they were
2
shaking-down to finance their other crimes.
3
We will need to prove exactly what she does, knows, plans and intends for Remington,
4
however it is known that her purposes are evil, criminal, her attitude is nasty, and she is
5 presently very angry with Remington (according to Gans in June 2016), and inferentially may
6 have been convinced or probably duped by Gans that Remingtons property was never
7 contaminated, and therefore he has no valid case. Hence, they will win any day now, as Gans has
8 assured her for about eight years now.
9 Consequently, obviously and as directly threatened by Gans, she is ANGRY at Remington
10 now, and presumably that Remington is still fighting obstinately with determination, babbling
about justice and related scientifically technical matters, which she has never seen and obviously
11
does not even understand.
12
In any case, whatever her views are or their basis, she has involved herself very deeply in
13
these litigations for many years, has read most of the same documents that Remington is read, and
14
therefore knows all about Gans criminal enterprise, or she should know. In other words, she now
15 has the obvious criminal intent to crush Remington in terms of the Enterprises stated
16 objectives, and it is her that controls Gans fraudulent defensive strategy, and it is her alone that has
17 the power to end all this instantly, or continue it forever. She finances every multiple perjury,
18 artifice and tricky, creative criminal scheme that Gans conceives, and therefore clearly assists Gans
19 in setting and achieving all the evil, unethical and unlawful objectives of this enterprise, that it is
20 sworn to accomplish. Written and oral discovery will be needed to determine exactly whose evil
and corrupt motives and plans control and make this enterprise function efficiently, HERS, Gans
21
or someone elses.
22
Remington knows, understands and has been involved with Gans detailed explanations,
23
detailed time sheets and justifications for his every act, all day every day in 10-15 minute
24
increments of time, plus his expenses, to the penny. He does that in order to get paid the hundreds
25 of thousands of dollars for his time he has accumulated. After the 10-15 years Lawrence and Gans
26 appear to have worked together, Remington has seen that he can put down just about anything and
27 get paid for it ONCE, if not twice, as per many examples of double billing, from 2009. Remington
28 even complained of some of that to Lawrence then, but she undoubtedly ignored Remington as
some kind of an angry and unreliable, bitter kook, and thereafter she let Gans continue to get away
95
with financial reimbursement murder these last seven years presumably. An irresponsible
1
employee that writes checks for a billionaire has no scruples or concern for how the money is spent,
2
not spent as requested and if the billionaires money is often reimbursed, or paid to Gans, for many
3
expenses which should not have been charged to Lawrence at all, who cares? They have plenty of
4
money, too much money and as long as that unlimited money is funneled from Lawrence to Gans
5 for any corrupt RICO protective racket that he requests, justice cannot be served here. Hence, this
6 RICO action became necessary in federal court, or state court if it fails here for some reason.
7 In 2009, Remington proved that Allied was being defrauded by the Mitchell firms padded
8 bills, inflated statements of ours, hundreds of dollars of charges for motions (for which the county
9 charge nothing, such as disqualification motions and many others), and double billing, i.e. charging
10 twice for the same hours work and billing Allied (and then Remington on top of that) for personal
time and/or work on other cases. All of that was fully documented with respect to the Mitchell
11
firms $12,000-$15,000 build to Remington in their first special motion fee billings, which due to
12
Remingtons analyses and proofs of fraud were reduced by judge Marilyn Miles to about $4500.
13
Irritatingly, it is obvious to Remington that Gans gets paid and reimbursed for anything that
14
he deceitfully writes down on a piece of paper, whereas Remington gets nothing, no matter how
15 justified his demands or needs may be.
16 In other words, every single corrupt racketeering enterprises act by Gans, as explained
17 throughout these documents, has by necessity been fully explained to, reported to in writing and
18 justified to Linda Lawrence of Allied insurance, The Big Boss here, that pays all the bills as
19 explained in Gans likely more self-serving words.
20 To Remington, Allied is ultimately, legally, morally and really responsible for what their
agent Gans does and also Lawrence is deeply enough involved in the detail of the above soldiers
21
illegal acts to be fully responsible and very intentionally implicated here. Implicated here, as in
22
prison time. In a just fantasy world she would share her jail cell with Gans for a few years,
23
while they talked about how they screwed Remington good for a while. Undoubtedly Allied and
24
Lawrence will have dozens of insurance related loopholes and escape clauses, however Remington
25 does not believe that they are innocent victims of Gans and Mathsons' frauds and criminal acts, as
26 Lawrence is inherently part of the highest command structure of the enterprise, and very arguably
27 is the single highest level of all. If that turns out to be true, after written and oral discovery, and
28 after several witnesses such as Plotz turn states evidence to the DA, then Lawrence could be in big
trouble here. Similarly, no prudent insurance organization could condone the criminal activities
96
propagated by Gans, Lawrence and the rest of the named RICO defendants, and therefore they
1
should not be implicated in this enterprise, are likely not guilty of criminality here, or the
2
commission of any predicate acts, and hence they are not presently named.
3
In any case, it is a fact that Linda Lawrence, or obviously whoever else has replaced her, if
4
that has occurred, fully controls the enterprise 100% because it thrives only on huge sums of money
5 and not because it has a just basis and purpose. If she stopped funding it, Gans RICO enterprise
6 would die a very sudden and very painful death in several days, because only 2-3 members would
7 continue-on battling, tormenting and destroying Remingtons property, just for the fun of it, and
8 without Gans providing legal cover they would wind up in jail within a couple of weeks. Mathson
9 and some of his gang buddies attack and damage Remington merely for the sport of it, mostly free
10 of charge, however Mathsons recent $20,000 elicit payday from the Farmers extortion described
herein, is still being worked-off in effect.
11
Until someone at Allied who is older and wiser, or until one or more RICO gang members
12
decide to expose their leadership, to avoid prison for themselves, and to tell the truth about some of
13
this, Lawrence is named as a very, VERY prominent RICO defendant, second only in importance
14
to Gans, but whether shes second anyone is open to debate.
15 Although Remington alleges above that Gans is the true Godfather of this enterprise and that
16 Allieds manager Lawrence probably (or at least maybe) has not been instructed on all the ruthless
17 corrupt suborning of perjury that Gans systematically and meticulously coached into his witnesses;
18 and, although Lawrence may not know everything here, she obviously knows enough.
19 Enough for what, will now be up to a federal judge, jury, local criminal investigators and in
20 all probability parallel state RICO proceedings.

Gans explicitly told Remington in the middle of the second floor courtroom corridor, in
21
June 2016 that Lawrence, et al (THEY) were very mad at him and perhaps writing $3-$400,000 of
22
checks to Gans for his frivolous corrupt defense might have had something to do with that. We will
23
see. Meanwhile, Even though Gans has possibly conducted a more corrupt Enterprise here than
24
even Laurence realized, she is known to be a very sophisticated manager and Remington believes
25 she knew and certainly shouldve known that Gans was up to no good up here. If she has a defense
26 of that type, clearly she is perfectly capable of presenting it, and would be expected to have about
27 five of their best attorneys assisting her with it. Thats fine, and it is obvious that the insurance
28 lobbies have managed to get hundreds of favorable statutes and probably useful decisions through
the legislature and courts, which we will no doubt become familiar with quickly. But, as above
97
thats now up to this federal court and hopefully ultimately a jury to sort-out, after substantially
1
more discovery. Meanwhile, based on what we have learned to date, Lawrences criminal
2
violations in this RICO case include without limitation:
3
2. 18 USC 1951, extortion.
4
Linda Lawrence is implicated and complicit here at the highest planning, management and
5
financial levels to the full extent that Gans, or anyone is. Gans crimes of extortion have been
6
described in detail above and he issued the direct orders to his soldiers as described.
7
But, given the level of detail that Gans, Brisso, Plotz, McBride, etc. from the Mitchell firm are
8
known to provide to Lawrence on at least a weekly basis, with their time allotted to 1/10ths of an
9
hour, it can be inferred, that Laurence is not blamelessly ignorant of this RICO Enterprises alleged
10
crimes, as she may attempt to portray. Lawrence likely did not master-plan any of Gans
11
Enterprises blatantly corrupt tactical steps, but she is known to be creative, interested and
12
aggressive enough from our various meetings and encounters to be familiar with all of the
13
objectives of Gans enterprise, which in their simplest form are to, without limitation:
14
a. Crush Remington fully, 100% without mercy, Regrets or any quarter;
15
b. Avoid paying-out one penny to him for any cleanup, or any other damages whatsoever;
16
c. Avoid any inkling or inference of guilt or responsibility for even one cubic yard of contaminated
17
debris which they admittedly meticulously placed on Remingtons property, and then buried;
18
d. Punish, torment and mortally injure Remington to the full extent possible under the law, and
19
after that do not be afraid or above using the extra-legal procedures which Gans is now very well-
20
known for; and,
21
e. Thereafter get a gigantic monetary judgment against Remington for all defendants costs,
22
sanctions due, then sue Remington into bankruptcy and simultaneously sue him for punitive
23
damages in a malicious prosecution lawsuit, and hope that he dies during those processes, and that
24
his heirs are not so determined.
25
Lawrences and Gans scorched-earth plans have been clearly presented to Remington by
26
Gans in several Conversations during 2016 in various documents and he has also made them clear
27
in pretrial oral arguments, but principally by observing his actual actions and threats objectively in
28
their totality.

98
1 Remington, on the other hand, merely seeks remediation of this property, back rent, the
2 numerous types of damages listed herein, and now triple those under RICO.
3 Hence, at the moment the parties, armies and enterprise that oppose Remington are at an
4 impasse, which could go on indefinitely without strong, neutral, unbiased judicial management and
5 guidance. That sort of judicial management has been absent in Humboldt County State Court for
6 more than a year now.
7 3. 18 USC 201. BRIBERY, at least a dozen incidents of varying severity are alleged by this
8 enterprise, which is 100% knowingly financed by Linda Lawrence. As alleged above, Lawrence is
9 not that young, flirty bimbo she pretends to be at first meeting or glance, and has proven to be
10 highly crafty, tough, very experienced, MEAN, ruthless and vicious and perhaps after discovery,
11 relating to all details of Gans corrupt activities, we will determine shes really also a criminal at
12 heart. All of her motives, detailed knowledge and intent will not really be accurately knowable to
13 Remington until after we defeat defendants anticipated extraordinary attempts to prohibit her
14 deposition. Ultimately, this court will need to decide on his own if it wishes to allow her deposition
15 are not over defendants protective orders, etc.
16 In Remingtons well-studied opinion, there has been considerable bribery on the defendants
17 side of this case, and in addition to the criminal activities of alleged, there has also been borderline
18 extortive horse-trading and numerous exchanges of money or influence for something else of
19 value, and in essence what could also be characterized as a quid pro quo has occurred here in many
20 ways, for many years.
21 As hypothesized above, it is unlikely that Gans, et al, have revealed their darkest illegal
22 enterprise plans and serial criminal acts to Lawrence, regarding all of their numerous individual
23 violent and destructive felonious acts or revealed most of their predicate acts to anyone. They are
24 secret, and not widely shared with anyone. Therefore, Lawrence may be able to successfully argue
25 that she is not individually responsible for Gans criminal misconduct; but, when it comes time to
26 pay treble damages, Lawrence and her massive financier and legal protector Allied is likely to back
27 Lawrence, 110%, whether justly or not, we dont yet know. At some point the court or jury should
28 have to determine a reasonable and fair formula for exactly who is responsible for all of these
damages, with so many people involved. Lawrence and Allied represent the Mathson and Gans
99
1 faction; however, RAO and Kluck likely have a different insurer whoever that may be, and that
2 insurer, plus Olson personally should be responsible for at least a THIRD of the damages here.
3 Today, Remington might argue that Gans as an individual is responsible for one third of the total
4 damages here, Mathson, Allied and Lawrence for one third and the RAO faction should be
5 responsible for at least one third, since they are arguably the chief beneficiaries from this entire
6 corrupt background and present day enterprise. Although, arguably Gans has probably benefited at
7 least as much as Olson, by now, from this entire sad, illicit and criminal affair.
8 See number 17, far below, somewhere after page 530, for A Listing Of The Damages
9 Sustained By Reason Of The Violation Of Section 1962, Indicating The Amount For Which
10 Each Defendant Allegedly Is Liable
11 4. 18 USC 1341. Mail Fraud, overlapping with violations of California B & PC 17, 200, et
12 seq), AND
13 5. 18 USC 1343. Wire Fraud, including internet, email and phone frauds.
14 Linda Lawrence is complicit with Gans planning and direction of this RICO enterprise as a
15 direct and personal actor. Also, Lawrence is an interstate business person who wrote checks, sent
16 emails and letters (all of which cross many state and probably International lines), made interstate
17 purchases, traveled interstate and made numerous related enterprise phone calls (and send emails)
18 to her home offices in Iowa and elsewhere.
19 Lawrence is clearly implicated under RICO as an interstate monetary laundering participant,
20 who occupies the very top of the pyramid and thus is arguably the most guilty participant in this
21 RICO enterprise. Gans is just a greedy opportunist and lazy, unethical, largely mediocre lawyer and
22 criminal who is taking Lawrences free money for as long as she keeps her unlimited allowances
23 coming. For a weak unethical person, unlimited free money, like free casino chips is a hard
24 temptation to resist and Gans has made no known or visible attempt to ever do so.
25 Linda Lawrence is the single most indispensable member of this racketeering enterprise.
26 If you remove Gans and Brisso, then Plotz would replace them in a heartbeat, possibly with a more
27 legitimate, but much weaker and dumber racketeering enterprise, perhaps not sworn to totally
28 crush Remington, and in all probability with less objectionable predicate acts as its basis.

100
1 Remove Lawrence however and her obvious over-zealous 110% belief in all of Gans plans,
2 promises, misrepresentations, lies and explanations about how his crimes are not really illegal, etc.,
3 and things would change here completely. Obviously Lawrence believes all Gans hype, bullAnd
4 fraud about these cases timing, his perennial grossly under-estimated expenses of winning them
5 and how soon all this will be over, etc. The fact that Gans has grossly understated the time required
6 and costs of these Remington litigations by (only) several hundreds of thousands of dollars and 5-
7 10 years apparently, all NOT surprisingly to his great financial benefit, is apparently not very
8 significant or important to Lawrence. Gans formulated and got-on this gravy train in December
9 2007 and never did he have a better money making idea for himself, nor is he ever likely to.
10 If Allied fired Lawrence, as a prudent executive might certainly consider, and brought in an
11 objective normal insurance account representative, said new representative might attempt to get
12 real and wonder why this case was not settled in 2011, for under $150,000 as it was on track to do
13 for several days, and at that time Gans and Mathson, et al ALL fully acknowledged their liability
14 and culpability for their trespass and contamination for at least that remunerative amount, which
15 they now have withdrawn, and reduced to zero. Meanwhile, Remington has accumulated a large
16 amount of additional costs, general and special damages, not to mention the fact that he has also
17 almost been killed by the contamination and its derivatives, on several occasions, which is also
18 worth something.
19 Gans just got totally greedy with his illicit, perjury based August 2011 federal Protective Order
20 motion and subsequent Summary Judgment Motion, Order and technically-based judgment. Gans
21 garden-variety deceit, subterfuge, impressively consistent false logic (which always result in false
22 conclusions), material factual mischaracterizations, overall fraud and perjury were all readily
23 bought by an inexperienced, easily tricked federal magistrate, who never fully understood the
24 salient facts on the ground of the first federal case. That was because said magistrate believed Gans
25 false statements of the facts, and the frauds generalized in the previous sentence, and there was
26 nothing Remington could do to alter that series of grave magistrate errors with no hearings, no
27 dialogue from either litigant with the magistrate of any kind permitted or possible, and no known
28 method of motion procedure to accomplish that, after August 2011, when the magistrate clearly and
single-mindedly canceled all hearings, the scheduled trial or pretrial proceedings in the
101
1 knowledge that he intended to dismiss Remingtons case back to state court, and no factor argument
2 from Remington was going to change that. Once that biased intent was formed there was no way
3 for Remington to present any refuting fact, which alternative facts would not have changed the
4 magistrates mind in any case, since his bias for Gans and against Remington was permanently and
5 in alternatively formed around August 10, 2011.
6 Obviously, the magistrate was bored and impatient with the case and wanted it to be
7 determined only in state court, and therefore ruled accordingly and permanently before August 20,
8 2011, and never considered altering that erroneous series of conclusions throughout the three
9 reconsideration motions over the next eight months.
10 6. 18 USC 1503. Obstruction of Justice. We have already pretty well-established that Gans has
11 no honest scruples or ethics, however exactly what Lawrence knows and when she knew it is today
12 still somewhat in doubt. Remington mentioned above that there are several known, obvious
13 committed, career criminals, plus some other inferred Enterprise members of possible borderline
14 criminality in this case, such as possibly Nelson, Randall, McBride, Joy Mathson, Costa, Plotz, etc
15 for example, that may be well-served to cooperate with the DA in attempt to exonerate themselves
16 and save their career. Why go to prison for Gans just because he is lazy, weak, sub-par as an
17 advocate and psychopathic?
18 a. Upon reflection here, what is Lawrence going to do here now? She is completely surrounded
19 by and enveloped in bribery, intimidation, threats, coercion, exaction, felonious altering of evidence
20 and over 100 cases of felony vandalism, burglary, criminal mischief and the many other predicate
21 acts described herein, and we havent even got to most of them involving JOHN MATHSON
22 especially, and people like Olson, Randall, potential violent assassin Skillings, and all Gans
23 perjuring witnesses, etc. IF Remington gets killed here, obviously he hopes that all 40, or so
24 named enterprise members get life and a couple of them get the death penalty, however as
25 regarding Lawrence, where she fits in to all that potential punishment is presently unclear.
26 Lawrence doesnt need Remington to give her advice and likely has 200 Sacramento-based
27 lawyers to help her successfully battle Remington, protector her, obfuscate, complicate, get this
28 case dismissed and attempt to bury Remington further. If that burial turns out to be a real one, she
will definitely be at the top of the list to serve prison time, but maybe she can call-off Gans
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1 mobster soldiers, especially Skillings, Mathson and Kishpaugh. Remington certainly hopes so,
2 more for his own sake than hers.
3 Hopefully, she has noticed over the years, (for example with Nixon, Clinton ,Trump to name
4 but three) that the cover-ups are often, and probably usually, the worst and most easily prosecutable
5 part of many crimes and therefore very often comprise the most important violation., which is most
6 responsible for the ultimate punishment. Cover-ups ARE obstruction of justice, and are one of the
7 several dozen types of obstruction presently going-on here in this RICO case, which obstructions
8 peer to have been adequately particularized, but if not many more details are and will be available
9 shortly.
10 b. The federal cover-up will arguably be the worst crime. Remington assumes and counts on
11 that being the case. That is, the case here now is primarily and most fundamentally ABOUT
12 the cover-up of all these RICO predicate acts described herein, and obviously well now see
13 very frantic covering-up by Gans and his closest associates, clandestinely calling RICO Associates
14 on the phone, swearing them to secrecy and additional perjury, and shredding all incriminating
15 documents, which they can initially find, etc. Whether Lawrence participates in all that very
16 obviously up-coming corruption, deception, lying to investigators and the court, and worrying about
17 who will be the first Enterprise member to break and decides to finance the cover-up for
18 additional hundreds of thousands of dollars, remains to be seen. Maybe shes smart enough to pull-
19 out now, however that seems doubtful since she, is totally emboldened and arrogant from her
20 unlimited funding and unlimited legal protection by the best insurance lawyers in the country. Also,
21 like Gans, who apparently must fully control her, she now has a personal unprofessional
22 vendetta, in part to save face with her superiors after all these years of wasted money, to
23 unconditionally WIN these cases quickly. Like Gans, she too is sworn to defeating Remington no
24 matter what it takes or costs, crushing him until he begs for mercy and forgiveness, gives-up all of
25 his just contamination lawsuits, or preferably just dies. Over the next few years, hopefully the trier
26 of fact will decide that paying huge damages, a substantial fine to the government or court, and then
27 going to federal prison for a significant term, would be a just result for her cooperation with and
28 participation in those Lawrence-Gans planned and produced mafia-like corrupt activities and
federally unlawful purposes.
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1 Will she decide to tell the truth about what she knows in order to avoid prison time and sinking
2 in Gans leaking criminal dingy? When the Eureka or federal district attorneys contact her what
3 will she say? How she responds to her imminent written interrogatories will soon be known, likely
4 even sooner than any DA queries, as we begin planning to lay-out a web of continuing covering-up,
5 and fraudulent deceptions among the 40+ Enterprise members. As explained above and throughout
6 all of these documents, Gans and the RICO enterprise committed several dozen state crimes and
7 perjuries as explained. Now they will be required to consistently enact, confirm, corroborate and
8 then repeatedly further reconfirm the veracity of all of that very extensive 2016 fraud, perjury and
9 false evidence, etc. Remembering the lies they told to the jury before and what the false reasoning
10 written by Gans was then is difficult for anyone to do, and with this sorry rag-tag bunch of Westgate
11 hoodlums, successful continued perjury will absolutely now be exceptionally difficult to sustain.
12 Remington believes that it will probably be impossible for several of the current state perjurers who
13 now must accurately repeat that consistently with their 2016 sworn testimony, with the added
14 anxiety this time of realizing that Remington understands their perjury and has been preparing for it
15 for several years. Additionally, it will not be very relaxing or fun this time, like it was in 2016, when
16 they realize that they are likely to go to prison, even if they are able to consistently repeat their
17 perjury; however, if they fail in federal court or discovery to get it exactly INaccurate (the exact
18 same way Gans got them to fabricated and then memorize it before) and incorrect as Remington
19 and his supporting attorneys expect, then prison for several of these RICO members would appear
20 to be a certainty.
21 c. The utter brilliance of RICO is that only one of the lower echelon members of this
22 enterprise needs to crack fully. Only one of them needs to decide that prison is inconvenient
23 and not really for them at this time, in order to bring down and totally collapse the entire
24 Enterprises command and leadership structure. Just one person needs to tell the truth, either
25 accidentally or intentionally, and decide that they have more important things to do at home with
26 their family and children than to spend a year or two in prison, plus pay tens of thousands of dollars
27 in fines, and suffer total humiliation, public ridicule and indefinite, and probably lifelong
28 deleterious career and community repercussions. That would be particularly true for all of the

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1 attorneys, professionals and others with immaculate professional reputations and pristine,
2 unblemished chronologically flawless resumes and careers to preserve.
3 Thats the beauty of Gans racketeering enterprise and the entertaining mystery now will be
4 which of these named individuals will be the first to crack and decide that they have less to lose
5 by telling the truth about what they know, than by sitting around worrying for the next several years
6 and waiting to see who will be the first to implicate this whole illicit gang. Is there really that much
7 love, reverence and supreme respect for The wonderful and kind Gans to spend 5-10 years in
8 state prison? It would appear not. As explained elsewhere, specifically where individual RICO
9 racketeering enterprise defendants and near defendants are discussed with particularity, Remington
10 has his suspicions and predictions based upon the solid evidence and understanding of the
11 personalities involved, related to which RICO members are most likely to crack and turn-in their
12 fellow potential fellow co-conspirators. Those predictions are not really conclusory, but are based
13 on human psychology and an intimate knowledge of some of these participants, primarily; however,
14 in any event Remingtons opinions may not be that important now, and therefore will not be
15 repetitively speculated about here.
16 Some of the rich RICO defendants here, which are probably about half of them, will scoff at
17 the fines but not at the prison time. When you study the RICO act cases, prosecutions and
18 convictions, you find that very often when the first person cracks, grudgingly tells the truth,
19 explains what Gans made them do and say, RATS on the criminal, racketeering organization,
20 you discover that ALL members are interactively implicated, who can be reasonably associated
21 with the enterprise. That the implication can obviously be accomplished by numerous means
22 including prior sworn testimony, prior disclosure of Gans intent to use numerous individuals as
23 witnesses against Remington and the bogus and fraudulent lawsuit DR 080669, or because they
24 received payments from Gans and Lawrence for past or perspective services, all of which are
25 always for work 100% consistent with the expressed in established RICO purposes and objectives
26 here. Like a house of cards, the whole RICO enterprise can fall when one card is removed, fails or
27 decides that it does not want to continue to be a structural member holding-up the rest of the
28 flimsy conspiracy, or house of cards, in this analogy. ALL are then guilty, and all are then held

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1 jointly and severally responsible by the court under federal law for all provable Remington
2 damages X 3, Plus whatever fines and other penalties the court and jury assess.
3 d. WHO was paid here by Lawrence, Gans or any of the 40+ or so enterprise members actually?
4 Who else was ready to lie for Gans and the enterprise and is now lined-up to testify in the next state
5 trials and what was written for them (i.e. for Randall, Olson, JOY MATHSON, Ferriman, Gwinn,
6 McBride, Plotz, Schwartz, Pulley Skillings, et al) AND How were they coached, and what written
7 proofs of that exist?
8 e. Joy Mathson as mentioned above, is especially interesting as she is now only marginally
9 implicated here so far, has shown a slight propensity (comparatively speaking) for attempting to tell
10 the truth, and fortunately for her she was not called at the August 2016 trial, where it was obvious
11 she was going to perjure yourself, yet miraculously managed to avoid that. She could surprise us all
12 by telling the truth and implicating the enterprise. Of course, ostensibly less painful, until they all
13 get caught and go to jail for participating in this conspiracy, would be to just shut-up
14 Remington by killing him, hopefully in some humane and non-painful manner. But, by the time
15 that becomes a viable executable plan, the Humboldt County DA, to the extent that one can be
16 found who is not directly and in all terribly under Brissos total influence and control, will be
17 intensely involved, all RICO Organization members will by then be under investigation, and
18 Remingtons enhanced surveillance systems should make that more difficult, but certainly not
19 impossible. Hopefully, Remingtons infrared surveillance cameras will gather enough information,
20 presumably in the dark, (when the cowardly RICO defendants assassins would be expected to
21 bush-wack Remington, and probably from the back) to at least arrest and convict any violent
22 perpetrators who attacked Remington or his family, but naturally, that will be of only minor
23 consolation to Remington, if hes already dead. However, since all enterprise members would do
24 hard time if Remington is killed, some of them may want to come forward NOW to guard and
25 protect Remington, and to especially watch-out for John Mathson and Skillings in the night
26 shadows. In other words, all members of this RICO enterprise are now on notice that the violent,
27 and muscle arm of Gans RICO enterprise are not a bunch of nice guys, are known to play
28 rough, and how violent they will now get is not presently known; however, the entire 40-named
RICO members and Associates identified and complained about herein should now be about half as
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1 nervous as Remington and his family will now be, until some of these violent soldiers are arrested
2 and taken-off the street.
3 Back again to Joy Mathson, who is now getting kind of old, cranky and sickly to go to prison
4 just to protect Gans, Plotz, Brisso and even her old, now quite useless, serial perjuring, old bugger
5 husband.
6 Hopefully, Shes got more important objectives, grandkids or some kind of and productive
7 work yet to do in her lifetime.
8 Nevertheless, this is all getting quite interesting, intriguing and exciting and it appears there
9 will be plenty of fear to go around now amongst the enterprises many members, after Remingtons
10 likely worse fears for the last 10 years, which also will likely continue to be worse until several of
11 these violent RICO gang members are behind bars. And as discussed, once several or even a mere
12 one has been convicted, how hard will it be to tie-in another dozen or more RICO associates?
13 This is actually getting quite interesting going forward throughout 2017-18:
14 WHO WILL NOW BREAK FIRST, TELL THE TRUTH, SPILL-OUT THEIR GUTS
15 TO THE DAs, AND FULLY IMPLICATE GANS, AND THEN A FEW DOZEN OTHERS IN
16 THE PROCESS: Costa, Kishpaugh, McBride, Plotz, Joy Mathson or another, presently
17 inconspicuously unsuspected or perhaps not even known yet? Are that bunch already in too deep, or
18 could they easily get immunity?
19 Only ONE needs to crack, but WHICH one? Who knows now? NO ONE. Thats whats
20 going to be really interesting going forward into the next new years, 2017-19. Kind of like the
21 Trump administration in early 2017, which is somewhat analogous to a new totally unexpected
22 train wreck every day. We know in advance daily that one will occur on some rail line, we just
23 dont know which one in advance, at exactly what hour it will occur or how many cars will go off
24 the track in the catastrophe, which seem to occur at least once a day at a minimum.
25 Subject to discovery will be Lawrences involvement in the remaining alleged predicate acts:
26 #6-16. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor;
27 7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite;
28 8. 18 USC 1513. Retaliation Against numerous Remington Witnesses;
9. 18 USC 1515 (a) (1,3 & 6) and (b), definitions here, such as Making false statements,
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1 omitting information, intentionally concealing facts and destroying material evidence.
2 18 USC 1952. Barring interstate travel with racketeering income, applicable here;
3 10. 18 USC 1956. Money laundering is illegal, ALL Defendants in this enterprise are guilty;
4 11. 18 USC 1957. Bars property sales and other purchases with laundered dirty money;
5 12. 18 USC 1961-4, et seq. Money laundering statute barring illegal profits investments;
6 13. 49 USC 5101, et seq, Improper permitting and placarding for hauling hazardous wastes;
7 14. 15 USC 2607, 2614-15 and 2642. Violations of hazardous materials hauling laws;
8 15. 42 USC 1983, Miscellaneous actionable deprivations of Remingtons rights by defendants.
9 16. 42 USC 102, Using and dealing in various controlled substances, including amphetamines.
10 Was Lawrence involved in the day-to-day operations and details involving the above violated
11 predicate acts? That is presently unknown and will need to be discovered over the next few years.
12 For now, solely financing this entire criminal RICO enterprise, committing mail and wire
13 fraud, acting as a primary manager and CEO of this criminal conspiracy and inspiring, cooperating
14 with and financing the RICO enterprises bribery, extortion, exaction, coercion, intimidation, frauds
15 and helping to formulate the criminal objectives of the RICO enterprise, ETC, are sufficient to
16 implicate Lawrence as an individual RICO defendant and require her to defend her actions in these
17 cases, at a minimum.
18 RICO Statement, #2C-John Mathson.
19 We are now continuing with RICO Statement standing order form number two (2.): List
20 Each Defendants and their Misconduct. The first RICO defendant covered was Gans, who is
21 discussed at A. for about 75 pages; the second defendant was Lawrence discussed above at B.; and
22 Mathson is the third RICO defendant identified here, and is C. Like Gans, John Mathson requires
23 a lot of space, because he has committed more actual physical, destructive, direct, observable,
24 measurable damage-causing crimes on the ground, than all of the rest of them put together.
25 1. 18 USC 1951, Hobbs Act EXTORTION: Mathson has systematically, deliberately and
26 believably caused long-term FEAR in Remington and his entire family, for 8-10 years so far,
27 as below.
28 As discussed throughout these documents, John Mathson has been Gans chief soldier,
criminal and violent perpetrator for several years. Although Kishpaugh and Skillings also live very
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1 close by, Mathson resides only 10-feet from Remingtons property line and is unable to restrain or
2 control his hate for Remington and his entire family. As a result, Remingtons wife, daughter, son-
3 in-law, brother and grandchildren are afraid to go over there at all, because Mathson is always
4 lurking, watching, peeping, frightening everyone with surprise flash pictures which simulate
5 gunshots and unexpectedly popping his head through a secret door, to see if he is being watched
6 before he lets dangerous and/or violent animals into Remingtons rose gardens, at will, where they
7 charge and startle us all and are potentially destructive to the 3-8-year-old girls.
8 Mathson has fully proven his courage, ruthlessness and insensitive psychopathic
9 personality, over the last eight years, and there is now no doubt to Remington and the entire
10 enterprise that John Mathson will commit literally any crime of property against the Remingtons,
11 but so far happily he has not performed any direct acts of physical violence against Remington, or
12 his wife and grandchildren. Violence and potentially major additional felony criminal acts appear,
13 based on presently discovered facts, to be Skillings specialty, who is presently characterized as the
14 Luca Brassi of Gans enterprise. John Mathsons' specialties are, without limitation in this
15 context: burglary; theft; Malicious mischief; felony vandalism of exotic plants, Burl Tree fixtures
16 and property of all sorts (PC 594-625); Evidence spoliation; Perjury and lying about any subject
17 with highly experienced, total calm naturalness; Multiple types of extortion; scaring, coercing,
18 intimidating and exacting Remington, his wife grandchildren, and his trial witnesses by various
19 creative, unethical and illegal means, including methods as violent as shooting a large metal pointed
20 arrows randomly into Remingtons yard; Cutting Remington security fences that are visually
21 blocked by trees just inside, making detection difficult, for the corrupt and felonious purpose of
22 enabling the entrance of dangerous animals as prescribed by and further delineated by Remingtons
23 SJI: CACI 464; Actual and daily threatened Arson, via smoke; Bad, intrusive and privacy invasive
24 photography, while Mathson still closely watches Remington DAILY, all his activities and all
25 visitors to Remingtons estate, from a variety of secret hiding places built like duck blinds.
26 Mathson still patrols all adjacent streets and also his vandalism and deer feeding paths, which
27 surround Remington and the Burl Trees property, almost daily. Mathson watches Remington and
28 his family every day and all day in daylight with intrusive and invasive flash camera, and
inferentially a gun, constantly in hand, and at night Mathson watches with infrared surveillance
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1 devices. Remingtons property is not public and Remington has given no consent for Mathsons
2 clandestine, but highly intrusive flashing surveillance activities, and has an expectation of privacy
3 in his very private fenced-in dense gardens. Whenever Mathsons flash camera goes-off in the
4 peaceful darkness of Remingtons redwood forest, it simulates a shotgun blast with a silencer,
5 startling and scaring Remington and disconcerting and upsetting all of his visitors, especially his
6 wife Suzanne, three young grandchildren, Eve, Rose and Peach, and their mother Laurel, who
7 feels the most direct threat and protective responsibility to protect her young.
8 John Mathson is very determined to stop all of Remingtons activity of every type on
9 Remingtons property, ruin him financially, as Remingtons fence perimeter is about one mile in
10 length, and Mathson still energetically walks around it almost daily looking for the next place to
11 discreetly cut Remingtons strong impregnable fences so that Mathson deer can ravage Remingtons
12 gardens. Discreetly means that Mathson tries to cut small holes in densely wooded areas what are
13 difficult for Remington to discover areas, which allow he is trained deer to be able to access and
14 ravage Remingtons gardens for several days or weeks before the hole is discovered.
15 Remington keeps comprehensive photographically-based records of the dates and locations of
16 most fence breaks and has photographs of many of them, most before, during and/or after said
17 fence breaks. Mathson typically cuts through the fence or removes restraints at the bottom of the
18 fence so that deer and bear can easily enter, but he also makes sure that said holes are always big
19 enough for him to also enter onto Remingtons property itself, to steal Remingtons $500,000 of
20 good redwood and other burls, valuable tools and equipment, scrap iron, and to do miscellaneous
21 vandalism to irrigation tanks and lines, ranging from 1/8 to 1, to damage plants and house
22 windows, etc. Above all, Mathsons major objective is always to lead his trained team Deer Army
23 into Remingtons rare Gardens containing hundreds of varieties of deer delicacies, and to also let
24 large bears in which similarly regularly feast on the hundreds of tasty exotic species not available in
25 the wild, and which are definitely not deer resistant varieties. The last recorded Mathson-caused
26 bear and deer incursions were in January 2017.
27 The Mathsons' are rather skilled gardeners, and at least watch carefully and therefore know
28 when Remingtons 15,000 planted, non-native exotic species from all over the world, including
hundreds of varieties of roses, Japanese maples and fuchsias, etc. are at their peak of sensitivity,
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1 vulnerability, fragility, peak delicacy of tender buds, maximum flowering and ultimate
2 deliciousness for his tamed deer, and therefore Mathson leads his deer army in here, accordingly. As
3 documented elsewhere, just one big deer can eat-up 7-10 pounds of rose petals in 24 hours, which
4 are a lot of roses. That could also be 50 small roses, already struggling for survival in these
5 Northcoast soils, shades, droughts and proliferation of mildew blights.
6 As we have explained elsewhere, Mathsons Gans-ordered extortion using the above means
7 began in June 2008 and before that Remington and Mathson were good friends and confidantes.
8 Discovery of Mathsons and defendants contamination of Remingtons land 2006, caused
9 the Mathsons to begin fearing and hating Remington because before that there never was a cross
10 word or thought, at least in Remingtons mind. A few years later in discovery the Mathsons
11 explained that they were very jealous of Remington and his big house all along, but pretended to be
12 cordial and faked it well, until joy Mathson realized that Remington was discovering their criminal
13 secrets and obviously eventually would discover their entire catastrophically damaging
14 contaminated hazardous waste dump, which they had built on his property.
15 From the beginning, it recently has become clear that Mathsons threats, vandalism and
16 extortion were clearly intended to threaten and intimidate Remington and to make him afraid,
17 frustrated and encourage him to not develop the area adjacent to the Mathsons' or better yet to
18 move, before he discover the full scope of defendants dump. John Mathsons partially successful
19 arson attempt in 2008 may have had broader purposes, such as destroying Remingtons entire
20 facility and making it much easier for him to leave for good than to rebuild. In 2008, Remingtons
21 residence had a major fire started right at the doorway in some flammables, such as saw gas and
22 several 5-gallon plastic diesel containers, while Remington was several rooms away in his office.
23 Said serious fire caused many thousands of dollars of damages, very nearly enveloped the
24 entire structure before Remington managed to control it and put it out in about 10 minutes while
25 getting very seriously burned in the process, by a large blob of molten polyethylene falling on his
26 back and sticking there for a good 10 seconds. When the fire department got there, Remington had
27 the flames extinguished and there was only a huge amount of smoke throughout the building, but
28 Mathson was seen nearby, in the large crowd of neighbors that it gathered, chuckling and looking
rather pleased with himself. Mathson had extremely easy access to that area from his secret door in
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1 his solid fence, as frequently captured on surveillance video and this incident occurred several years
2 before Remington had discovered that door at all.
3 Instead, Mathsons vandalisms and arson, during which Remington was severely burned by
4 melting plastic dropping down onto his back, while fighting the fire before the fire department got
5 here, just made Remington angrier and increased his resolve over a longer period of time spent
6 writing and complaining about Mathson and said dump.
7 Although the scope and purposes of John Mathsons felony vandalism does appear to have
8 changed several times, it seems that the clearest statement of its purpose was made by Gans in June
9 2016, as fully paraphrased above, When he said an effect we will stop it (our criminal activity)
10 if and when you drop your lawsuits, [which you cant win anyway because we have
11 overwhelming power, money, witnesses and evidence in effect]. Remingtons wife has fully
12 bought into Gans extortion and is afraid of Mathsons Westgate gang of drunken hooligans and
13 vandals who apply extreme continuous pressure, 24-7 on Remingtons family. What is merely
14 trepidation and fear for Remington usually has become real frightened terror for Suzanne
15 Remington, great concern about the trespassing dangerous animals and resulting extreme
16 irritation for the tougher Laurel, and actual panic for the grandkids when they see bears with
17 young cubs, or huge deer lurking, lurching unexpectedly or charging in panic towards or away from
18 them, always surprisingly coming from unsuspected dense vegetation where they have not been
19 detected. The grandkids dont want to visit at all anymore, despite the literally hundreds of toys that
20 are there, but when they are dragged-over there about once in a months vacation, they now are
21 afraid and run rapidly into the house to avoid getting possibly eaten by a, or THE bear or just as
22 likely speared by a fleeing, horned Buck, or stampeded by a huge doe, protecting her young fawns.
23 As has been explained herein, the costs, injuries and damages to Remington are substantial
24 and consist of multiple varieties including emotional, physical, financial, especially in terms of the
25 enormous lost Burl Tree sales which are directly attributable to Mathsons criminal acts over the
26 last 10 years, and which continue at least weekly, and/or obviously until Remington disappears
27 from the site.
28 As a result of that, Bruce Remington (plus the rest of his most intimate family named above)
lives and works here in constant fear, dread and anxiety with the reality of being constantly watched
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1 by a stealthy, crazed and criminal evil aggressor that does almost daily costly vandalisms which do
2 extensive financial damage and are difficult to locate and repair. For example, it can take at least
3 three hours to locate Mathsons one or two cut-holes, and massive cuts in Remingtons lengthy
4 fences, every few days, in nearly impassable, steep terrain. Usually the deer stay hidden or sleep
5 during the day, and do not appear until about twilight, so that when Remington begins looking for
6 the fence holes, and/or calls in his deer chasing dogs, it is usually dark by that time. Darkness
7 makes finding the holes and repairing them quite difficult and requires headlamps, and significant
8 repair materials and tools brought down from the top of the mountain on steep, often slippery paths.
9 Also, as complained, the cost to replace damaged and destroyed exotic plantings and irrigation
10 tanks is extensive. Remington no longer has thousands of wholesale roses were propagated
11 miscellaneous species in his nurseries to replace the plants destroyed by Mathson.
12 The broken, expensive Anderson windows up to 6 x 2, with wood slats in an X pattern,
13 have to be specially ordered, professionally installed and cost hundreds of dollars each to repair.
14 Similarly punctured irrigation tanks, damaged vehicles and stolen Burl Tree machinery,
15 materials and inventory are costly to repair or replace, and no insurance is available for virtually all
16 damage that Mathson causes. Mathson has provably used very sharp-pointed heavy redwood
17 branch spears sabotaged tanks plus frequently shoots large ported arrows for the trees either at
18 Remington or randomly, which is yet to be determined.
19 Until recently, the Gans-Mathson corrupt co-conspiracy has been somewhat protected by the
20 attorney-client privilege. Now, however under RICO, and in view of these fraud allegations, the
21 crime-fraud privilege exceptions in the law will also penetrate some of the written Gans-Mathson
22 written communications, although since most of their criminal plans and orders were oral, we will
23 need to probe their criminal conspiracy at depositions and in cross examination at trials. Since
24 Mathson can barely write his name, such that Gans and Plotz do all the criminal writing for the
25 enterprise, and also because as explained above Gans and Lawrence make all of the bribery
26 payments to their experts, bribed and scripted witnesses, plus Mathsons friends and drinking
27 buddies, Remington will need more discovery in order to fill-in any predicate acts by Mathson
28 related to bribery or Mail fraud.

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1 4. 18 USC 1343. Wire Fraud, including internet, email and phone by John and Joy
2 Mathson. Both Mathsons' are in touch with all of their fellow soldiers by phone, in person and
3 probably by email as they plot and corroborate their suborned perjury, beginning in July
4 2016. Also considerable communication had to take place between John Mathson and
5 Skillings since 1998 and before, but most pertinent here and beginning by phone on
6 November 15, 2012 and continuing frequently into 2013, Mathson spoke to Skillings with
7 regards to Figas and his excavator. As this is a complex topic, it can wait for discovery and
8 trial cross-examinations for all its details and dates.
9 It is also presently unknown whether Mathson and the other co-conspirators communicate with
10 Gans and each other by email or just by phone. They use the phone a lot, in some cases they use the
11 US mails, however face-to-face with no witnesses present is Gans preferred choice, Remington has
12 noticed.
13 For example, John Mathson has frequently been seen to plot and scheme with Kishpaugh,
14 sometimes almost every day, which Remington knows because he often gets random views of the
15 Kishpaughs usually from along Westgate Drive, who live almost directly across the street from the
16 Mathsons. More detail about those communications is omitted here in the interests of brevity.
17 Costa, Skillings and John Mathson are all good friends and have all perjuriously collaborated
18 and conspired about How best to extort, intimidate, coerce, exact and basically punish Remington
19 in this case. The frequency and extent of that collusion and whether any of it now is independent of
20 Gans remains to be discovered.
21 5. 18 USC 1503. Obstruction of Justice. We established earlier that Gans has no honest scruples
22 or ethics, but John Mathson is certainly just as bad overall, and arguably worse. its kind of like
23 comparing the godfather to one of his chief murderous subsidiary family members, one which
24 personally commits more murders than the Godfather himself. In other words, John Mathson like
25 Gans is a very bad actor, gang member in criminal conspirator, but without the polished, well-
26 dressed sophistication, smugness, attorney privileges, fancy and false vocabulary, self-centered
27 legal protections or the arrogant, grandiose feeling of entitlement that he can break any law or good
28 faith convention that suits Gans convenience. In other words, John Mathson is the low class, beaten
down, crippled and disabled former maintenance union worker, whereas Gans connotes the exactly
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1 opposite impression of being a smart, clean-cut and arrogant winner. John Mathson is equal to
2 five or six others of the lowest level soldier in this RICO enterprise and he gets his hands dirty,
3 bloody (as needed) and has the anger, recklessness, stupidity and courage to risk imprisonment or
4 death in many of his activities. Gans is generally a coward and basically just an overfed, out-of-
5 shape, studious (with glasses), pseudo-intellectual type and inept Pussy (in ordinary local
6 parlance), and it is very doubtful that would have the nerve or the balls to personally execute many
7 of these criminal activities directly without his minions, soldiers and hoodlums. And that of course
8 is one of the purposes of a RICO enterprise which is to provide important division of labor where
9 some of them are the top level plotters, thinkers and evil masterminds and others are the ruthless
10 strong soldiers who specialize in physically executing the torture, Murder, arson, etc. which was
11 planned by the RICO leadership.
12 With the unlimited financial backing of Lawrence and Allied, Gans does not have to do any
13 of his own dirty work, can pay others to do it with their unlimited funding, so thats exactly what he
14 does do. In the case of Mathson however, Mathsons' palatable and intense jealousy and hate for
15 Remington and his wife and family, makes his serial felonies against the Burl Tree an act of great
16 joy, obviously huge personal satisfaction that requires no other compensation beyond Joy
17 Mathsons high praise and John Mathsons intense pleasure of imagining Remingtons pain, as he
18 must stumble around in the dark to find the holes in the fence, and then repair them by flashlight,
19 wire and fallen redwood branches, typically. Specifically:
20 a. John and/or Joy Mathson are believed to have a blood relative involved in the court houses
21 Superior Court bureaucracy. At trial, independent and discovered evidence of that will be presented.
22 b. Meanwhile, John Mathsons comprehensive systematic evidence spoliation has been a matter of
23 constant complaint for the last year, and has been thoroughly documented in before-and-after still
24 and surveillance video photos all over the dumpsite. Among other things they show, with time, date
25 and clear facial identifications: John Mathson raking-up redwood needles and then hand- depositing
26 them on top of asbestos pipes and other hazardous materials to visually conceal them from
27 Remingtons experts visiting the site that same day and/or the next day; Rolling pipes up the hill,
28 lifting them over the fence and then laboriously moving them through his gate into his backyard for
removal and disposal at an improper disposal site. Gans is also clearly seen supervising these illicit
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1 and criminal operations shortly after 8 AM in the morning, on surveillance videos as discussed
2 above.
3 Superficially, defendants argue: Whats the big deal? Remington wanted the site cleaned-up, so
4 now were doing it by hand. However, Gans and Mathson by removing the superficial top layer
5 and 1/10th of 1% of the worst debris, they are deliberately and deceptively just making the site look
6 ordinary, pristine and broom swept, so that when a jury, any environmental investigating expert
7 or court visits the sites, they will automatically assume that there is no contamination here. That is
8 because, what remains here now is substantially buried, 99+% invisible, or microscopic
9 bacteria. There are also many tons of carcinogenic dusts, silica and asphalt, etc., and thousands of
10 pounds of blowing very tiny, invisible to the naked eye, asbestos Chrysotile particles, that all take a
11 microscope to detect, once airborne. All of those toxins easily, and do get airborne and only have
12 100 feet on the prevailing winds to reach a densely populated neighborhood with hundreds of
13 young, old and other ages of residents, NONE OF WHOMS lungs can tolerate defendants airborne
14 toxins for long.
15 Cumulatively, John Mathsons' 2015-16 superficial cleanup and cover-up of his toxic waste
16 dump is about as Helpful, and equally as self-serving and potentially exonerating, as OJ
17 returning the night of the murders to mop-up the blood, use ammonia rags to wipe away any nasty
18 blood and fiber EVIDENCE off the gates, and remove any other conspicuous objects that might still
19 be left there, by the true killer, on the crime scene, such as possibly bloody knives, gloves, hats or
20 truck mats with multiple blood stains from multiple people. What Mathson has been doing on this
21 criminal dump and active crime scene is no different then OJ removing all incriminating evidence
22 from the murder scene before the police got there.
23 See 2011 California Evidence Code 956: There is no privilege under this article if the services
24 of the lawyer were obtained to enable or aid anyone to commit or plan to commit a crime or a
25 fraud.
26 Gans masterminded the evidence spoliation by observing that Remingtons entire case to a jury
27 (and conversely their defense) involves photos and whether the site looks contaminated or not. Is it
28 obvious, or did Remington just make all this up and take a di minimus few wheelbarrow loads of
good topsoil a few feet over the property line and manufacture a federal case out of it? That is
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1 Gans fundamental defense, based on the scripts he wrote for Mathson, Randall, Ferriman, Pulley,
2 Gwinn, Kishpaugh, et al. A false narrative and fiction, but how is a jury to know that, when the
3 dump is buried, broom swept, entirely underground and exhibits only visually invisible pollution?
4 Mathson has also lied to the sheriffs deputies investigating his criminal vandalistic extortions, e.g.
5 when he speared Remingtons Tank A, causing drought damages in 2000 sensitive plants and
6 requiring about two weeks to properly repair.
7 During the SOL trial, Mathson lied on the witness stand under direct and cross-examinations
8 for approximately 3 hours of transcripts. He and Gans think that they are now home free on that
9 perjury, and that Remington will never catch and prove their lies. However, we think we can prove
10 their perjury with a couple more years of foundation and clever preparation. With time to find all of
11 his relevant notes and records, Remington will be able to prove that he was not in town at all on the
12 cited days, Costas birthday, or on Mathsons land at all on September 12, 1998, or on any other day
13 in that month or year either.
14 A jury properly prepared in Voir Dire from the very first minutes, and knowing what to watch
15 for from Gans, Mathson and all their witnesses, will not be as nave and trusting of defendants
16 collective collusive lying as the August 2016 SOL jury was. We also plan to use a variety of well-
17 prepared cross-examination by omission techniques, etc.
18 6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor, which statutory
19 definitions are fully met here as discussed above. Mathson, et al, gambled they could lie at the SOL
20 trial and get away with it and did, so far. As to the big gamble that they could bury 2,000,000
21 pounds of hazardous wastes on Remingtons land, gross over $1 million in doing so, and then get
22 away with it forever, is now in doubt as the criminal enterprise begins coming apart. Defendants
23 collusive crimes worked perfectly for about 15 years, but now it is all coming unraveled and like
24 the Tell Tale Heart (Poe), the actions of many individual defendants, which we have variously
25 named (and of course we are watching very closely now), is giving them away each and every
26 time they write or say anything. Crime and Punishment also comes to mind as symbolizing John
27 and Joy Mathsons intentions, problems with their consciences, but hopefully not indicative and
28 prognosticative of their future plans, which if they do their worst, would be recorded in any case.

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1 7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite and
2 John Mathson is Gans star perjurer, doing it calmly, seamlessly and convincingly until he got tired
3 one day and forgot his entire script. Remington read the transcript of Mathsons fatal errors at the
4 trial to the jury, but it went over their head, because they seem to have formed their entirely positive
5 (and wrong) opinion about Gans case during Voir Dire and nothing could be done after that.
6 John Mathson, dutifully following his orders from Gans, has systematically watched and waited
7 for every major visiting expert that Remington has ever invited to the property has terrorized,
8 abused, yelled at, threatened and frightened away virtually all of the to some important degree.
9 John Aveggio, SHNs testing technician, Foget, Hoyos and her technician, Bruckner, Dr.
10 McEdwards and Remington, Alves and several other remediators where all accosted, harassed and
11 intimidated by John Mathson over the years. More than 10 instances of witness tampering and
12 intimidation involving Remington site visitors alone.
13 John Mathson of course also severely and prejudicially tampered with his own witnesses, giving
14 Pulley very false information about the toll of the Phil, when neither of the understood the extent of
15 the fill and neither of the had even done a minimal investigation of its lateral extent of Remingtons
16 property.
17 Also, it was John Mathsons initial false sworn testimony about the length, composition,
18 function of and crucial source of the important twin 6-inch drain pipes that really started the entire
19 present avalanche of false summary judgment statements by all of defendants experts Plus Gans,
20 Plotz and Brisso.
21 In winter 2012, Mathson also tampered with Remingtons car and was caught in the act of
22 breaking-in through Remingtons front gate in order to vandalize Figas one hundred thousand
23 dollar excavator sitting in Remingtons driveway.
24 In February 2016, John Mathson also deliberately removed and covered all exposed asbestos
25 on the dumpsites with redwood needles on the day before and on the morning of Dr. McEdwards
26 deposition, and only about 24 hours before Hoyos February 2016 deposition. As explained
27 elsewhere, that was witness tampering and attempting to prove to Remingtons experts, only an
28 hour before their depositions that there really is no dump here, no contamination, all Remingtons
photos are just a bunch of crap, and Remington has a worthless and frivolous case unworthy of their
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1 participation. Essentially Gans clever, ingenious and diabolical plan was to ask: What are you
2 going to believe, Remingtons 2008 photos, from eight years ago, or your own lying eyes at the
3 site itself and the actual reality of the dumpsites today?
4 That is Remingtons basic point here: a criminal racketeering enterprise with a clever leader
5 can eliminate all or most negative evidence, fabricate favorable expert testimony from both sides,
6 clean-things-up so the photography is favorable to defendants Big Lie, prove Remington is a liar
7 or just not credible in subjective ways to an inpatient and hurried jury, already inpatient in having
8 to deal with and listen to an amateur pro per litigant, Remington. Essentially, an unethical crook and
9 disingenuous advocate like Gans can turn Black and White, and make evil appear good while
10 briefly shining a spotlight on these individual material evidentiary issues. Thats exactly what Gans
11 and Mathson did recently in the 100 or more days of 2016 pretrial hearings and then climaxed that
12 with their August 2016 SOL trial performances. Now that Pandoras Box has been opened Gans
13 and Mathson, et al are now forced to continue their fraud, deceit, perjury and numerous other
14 related and supporting crimes indefinitely, until they all go to prison under the RICO Act.
15 8. 18 USC 1513. Retaliation Against multiple Witnesses by John Mathson, as above, below
16 and throughout. As alleged herein, Gans is the brains of the operation and the big
17 racketeering boss, but John Mathson and his lower level minions, friends and fellow retired
18 Mill union workers, are not blameless. The murderer who pulls the trigger also must be
19 punished, not just the Godfather that ordered that hit.
20 Here, Mathson had orders from Gans to watch every move that Remington made on his
21 property for many years, night and day, 24-7, and John Mathson took that order very seriously and
22 literally for many years. Doing that was mostly probably not predicate RICO acts. Terrorizing
23 Remingtons wife and grandkids perhaps does not violate any federal law nor does peeping,
24 leering and lurching-out from behind trees or bushes, or from a secret door taking flash
25 photographs in the near darkness, necessarily arise to an imprisonable offense. However, some of
26 what Mathson did, practiced, schemed and plotted then were or became federal law violating
27 predicate acts.
28

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1 For example, in December into January and February 2012-13 Figas intimidations were true,
2 pure racketeering syndicate operations extortive acts, causing Remington on the order of $50,000
3 in damages.
4 Kishpaugh could see Remingtons property best, but John Mathson also had knowledge of a
5 low-boy and excavator being unloaded and driven into Remingtons yard within hours of its
6 happening. Who saw what first and who did what when, will be a matter for future depositions.
7 Mathson himself could not see directly when Figas excavator was unloaded and driven into
8 Remingtons yard because those acts were concealed by 25-foot tall hedge and dense foliage, so
9 either someone else had to see the lowboy backing-in to Remingtons property for 15 minutes or
10 walk by the gate later and look through the one narrow 6-foot wide gap in a mile long perimeter.
11 Fortunately (for the enterprise), John Mathsons' daily routine of circling Remingtons
12 perimeter and walking by that narrow 6-foot wide gap occurred daily including on or about
13 November 22, 2012 and then on many, consecutive subsequent days, sufficient to warn his friend
14 Skillings and Ron Olson, President of RAO Construction about Figas imminent danger to them all
15 and to the enterprise. Bob Figas was the Enterprises greatest fear in 2012 and even today, because
16 in less than a minute he could, still can and probably will potentially undercover enough skeletons,
17 crimes, possibly evidence of murders, but in any case obviously horrible criminal dumping felonies,
18 which the entire Enterprises very concerned about, and which may be enough to send the entire
19 Enterprise to prison for quite a few years.
20 Whether Gans gave the orders to Mathson and Skillings to do whatever it took to get rid of
21 Figas before he discovered anything, or whether someone else managed the actions here, is
22 presently unknown, however John Mathson had to originate the information and get it to Skillings,
23 Olsen and Gans, and then someone among that latter three, who all new Figas, called him on the
24 phone initially and apparently quickly and rather easily did their very damaging criminal
25 intimidation, blackmail and major predicate act extortion of Figas which lasted several months and
26 into about June 2013. As above, Remington and the Burl Tree has suffered about $50,000 of
27 damages to date, however the active enormous slide only 50 feet from Remingtons extremely
28 heavy, many millions of pounds structure, is still active and still could potentially do another
million dollars of damages without much trouble and without considerable good luck.
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1 Future depositions and trials will be needed to evoke the exact words used by these participants,
2 but whatever defendants said to Figas was sufficient to turn a hard, logging boss and owner of a
3 wilderness yarding, logging and trucking business which employees up 150 Men, into a scared
4 rabbit, or pussy, so to speak. Figas left Remingtons land at Westgate so fast, in mid-project, and
5 without any winterization of the important gravel road which he tore up with his excavator, such
6 that after the first week of hard rain flowed-down his excavator ruts, a very, very serious landslide
7 occurred, as explained.
8 Figas left in a great rush and in a real panic and there was at least $15,000-$25,000 of
9 undone, specifically assigned work involving gathering, loading-up and trucking scrap iron to
10 Oregon, which was left on the table when Figas was actually desperate for money. Therefore,
11 whatever specific words Skillings threatened about revenge, retribution, bribery, and intimidating
12 extortion related to Figas transgressions, and specifically what exact fears Figas had about his
13 under-insured huge excavator worth at least $100,000, if not $175,000, caused by a couple brief
14 phone calls, will need to be further discovered at several depositions. Figas is still justifiably very
15 scared, even today four years later, reluctant to discuss all the details involved with this extortion,
16 and still is in great fear of defendants enterprise. During spring 2013, Figas was very afraid of
17 something specific, explained some of it to Remington but always inferred that hed be back, but
18 clearly he wont be back now, as something more has continued in this matter until 2015 when we
19 last discussed it in detail. Today, he seems to be permanently traumatized and has suggested a
20 replacement contractor for himself, in November 2015, which was Wayne Marsh, but when the
21 defendants heard about Marsh they promptly intimidated him also, and now hes afraid to work
22 here also.
23 This entire matter is now a very complex and difficult situation which Remington may need
24 the DAs office to assist with. For example, some form of protection or immunity may be needed
25 for Figas and simultaneously for some of these other witnesses involved in this matter, before all of
26 the truth is going to come out.
Plaintiffs every action, such as urination, is also, obnoxiously closely watched and
27
photographed daily by Defendants Mathsons (by numerous odd and creative ruses, photography
28
blinds and other devices); and, several times a year Defendants still continue to make irrational

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complaints to one governmental agency, or another, concerning cutting trees and brush, or the
1
recent harassment complaint to County Public Works, purportedly about Plaintiffs DANGEROUS
2
hedge (believe it or not), which pruning of that huge hedge is done by the County themselves, and
3
was once delayed a couple weeks due to THEIR vacation schedules. Meanwhile, the Mathsons
4
successfully complained to numerous unrelated, irrelevant County Departments, like Community
5 Development, resulting in lots of wasted time, a useless, unnecessary Demand letter to Plaintiff,
6 and phone calls to prompt one of their own County departments to move quicker to shut those
7 Mathsons up (you cant make this stuff up!). THUS, Plaintiffs primary enjoyment in life and
8 peaceful enjoyment and occupation and maintenance of his large estate and gardens have been
9 destroyed by Defendants.
10 The Mathsons also ALWAYS complain to the County Health Department whenever Plaintiff
does any lawful spraying with substances permitted in California, for weeds or fungi, like Round-
11
up and Heritage, or if he legally burns some garden debris, etc. Fortunately, most local agencies
12
are finally tired of Mathsons frivolous complaints and just ignore most of them now, without
13
bothering Plaintiff over every monthly complaint, about the above, or whatever they conceive of
14
NEXT. In short, the Mathsons are like neighbors from hell. AS JOY angrily put it in
15 2006: We dont want you living here and are going to get together with the neighbors and
16 DRIVE YOU OUT. That honest outburst by Joy Mathson was very prophetic and summarizes
17 what the enterprise has been attempting here overall since 2008, and in a criminal way since 2012.
18 That formulation is a nearly exact statement of the RICO enterprises present objectives, and
19 Ms. Mathson will get a chance to reiterate all of that once again during her federal deposition to
20 see if its consistent with her similar statements in 2010, but when she was less angry, than she will
be this time.
21
Whether any of that is parenthetically relevant to a jury considering emotional and punitive
22
damages, which WOULD NOT BE FINANCED BY PAPPA ALLIED IF AWARDED,
23
INCIDENTALLY, remains to be seen, however John Mathson, the former Mr. nice guy has,
24
since 2007, turned bitter and irrational in all respects and the Mathsons CERTAINLY APPEAR
25
NOW to BE A LOT LESS SYMPATHETIC TO A JURY, REASONABLE AND RATIONAL than
26 when this all began in 2006.
27 More specifically and criminally actionable with the appropriate EVIDENCE, Plaintiff now
28 has to inspect and patrol with a dog, his lengthy shared fence line with the Mathson Defendants
almost daily, rather than about monthly, because Defendants have recently and continuously
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violated and vandalized the barrier repeatedly in 2014. That vandalism occurs regularly by John
1
Mathson, (as above) and is being recorded by surveillance means, incidentally. Mathson
2
deliberately breaks the fence down, or cuts it, in multiple places, which his trained deer find easily
3
only 2 off their feeding path, digs deep trenches next to the fence on his side, in order to
4
undermine it or just CUTS its ground stakes (as per July 22, 2014) to enable his deer to quickly
5 finish the job by merely squeezing through narrow openings, which they do instantly. Mathson has
6 also frequently ripped-out or unraveled (to presumably cleverly avoid flagrant clipper marks)
7 entire large sections of fencing and/or started and finished substantial tunnels under said fence on
8 steep terrain, large enough for large deer and even 700-pound bear to quickly crawl through,
9 without a scratch. [ the above passage was written substantially in 2014, all that has continued into
10 and through December 2016].
Mathsons clearly observed photographically revealed objectives, as explained historically
11
above in detail, is to encourage and ENTICE large numbers of deer to invade Plaintiffs security
12
perimeter and then ravage and destroy his thousands of sensitive, delicious plants, most of which
13
are deer-delicacies, many are also now unduly weak and fighting for survival in this desert
14
anyway, and many of the fruit trees, including exotics like lemon, persimmon, cherry, peach,
15 serviceberry and unusual plum varieties, etc. are highly desirable to bears also. Over the years
16 Mathsons invaders have eaten hundreds of pounds of peaches, alone.
17 For example, during the actual first initial conceptual drafts (later postponed a year and a
18 half) of this document, way back on a dark November 23, 2012 night, at 8:30 PM, Plaintiff went-
19 outside rapidly and unexpectedly (obviously) to his car parked on Westgate Drive in his
20 driveway, to get something, and discovered none other than John Mathson lurking in the dark
directly at his gate, attempting to make a very quick limping getaway and looking-back furtively,
21
highly suspiciously, guiltily and VERY anxiously. No anger that night, just the pure unadulterated
22
look of FEAR, if not terror, of a brazen criminal caught by surprise in an imprisonable act, when
23
he thought that he was all alone. Normally, Mathson wouldve been alone at that hour and location,
24
and it was just random luck that Remington needed some tool that was kept in his cars trunk.
25 Mathson was clearly caught in the act of some unknown mischief, presumably at least
26 partly studying the structure of and tampering with the fences adjoining Plaintiffs main gate,
27 where holes are still seriously blocked by dense vegetation, and break-ins are unexpected at such a
28 prime location, but ARE AT a place where deer hang-out waiting for someone to leave the gate
open a small crack. Only minor fence loosening at the gate posts was noticed, and it is not
123
absolutely known today whether any damage to Figas huge excavator was actually done that night
1
or attempted because Remington did not talk to Figas for several days thereafter.
2
Whether Mathson got into the cab that night, did other sabotage to the hydraulic lines or
3
related damage, or whether he was right on the edge of doing so, is very likely, but not yet proven,
4
as discussed in more detail below.
5 Ironically and parenthetically, during the final cursory proof-scanning parts of this
6 document, on March 5, 2017 when Remington approached his front gate he noticed that someone,
7 presumably John Mathson had pushed various vertical supports out of place, broke some
supporting wires and opened-up a gap again at the gate just enough for a gigantic deer to easily
8
squeeze through, very similarly to whats in the above paragraphs. Remington went into the house
9
got wire, pliers and wire cutters, etc. and repaired the area very thoroughly to a much higher level
10
than it had been so that not even a cat could squeeze through anywhere there. But, when
11
Remington got to work Monday, March 6, 2017, something which would have had to have human
12 hands and an evil intent head again violently shook the right support says looked at from the
13 outside until they weekend and produced new gaps in the same area as the day before. This time
14 Remington just pushed everything back into proper position and supported it, however a human
15 saboteur with the strength of a 220-pound man can shake, weaken and break supports and did so
16 here. The next day that it happens Remington will reinforce it much further to show Mathson that
17 he is aware of what he is attempting to do and exactly where he is doing it.
What is totally clear is that Mathsons guilty and hasty flight in 2012, indicated strongly
18
that Plaintiff arrived just in time to avoid whatever insidious mischief Mathson was actually doing
19 when he was caught! In 2017 there was no such hundred thousand dollar machine sitting 20 feet
20 away, so it was probably a predicate act of attempted arson, whereas the 2017 vandalism and
21 malicious mischief was more benign, but is a continuation of the Enterprises extortive campaign to
22 make Remington an offer to leave this land and abandon it to the Mathsons, which at some point
23 you will not be able to refuse, because hes too weak and old to battle the enterprise from a
24 sickbed.
Well learn much more about Mathsons excuses for all of the above events plus at least 100
25 others which are completely documented with photographs, at his next deposition. When he begins
26 to lie about all of them, eventually we will trip him up with impeachment surveillance video.
27 Inferentially, John Mathson was either getting ready to trespass, or perhaps had just
28 completed a trespass, either through Plaintiffs unlocked gate or was caught in the act of removing
the attached ends of fences from the concreted gate posts, which had been disturbed, and where he
124
had sabotaged them previously in 2011, at that an exact spot, once reinforced further, making
1
another break-in obviously by HUMAN tools. Mathson historically had previously cut and also
2
unraveled Remingtons security fences in that same area (and also 10 farther away in another
3
year), immediately on either side of Plaintiffs often locked main gate where some of the multiple
4
bear-proof fences are somewhat weaker, because they are reinforced (but also obscured) by a thick
5 20 tall hedge, such that holes made by Mathson for unauthorized entry are difficult to notice, see
6 or find, and are thus generally unexpected, until now. Mathson has also sabotaged Plaintiffs mile
7 long fence in at least 100 other specific places, times and manners as documented and which will
8 be painfully developed at the trial for emotional and punitive damages, to see Mathsons attempted
9 innocent looking perjured reactions, to buttress our other aforementioned Deposition perjury
10 proofs involving witnesses. Perhaps a jury will interpret John Mathsons continuous efforts to
drive plaintiff from his property, which he CANNOT now leave, when his property is actually now
11
already rendered unsalable due to Mathsons contamination, negatively and unsympathetically.
12
Continuing as to the 2012 incident, more serious, that SAME November 23d night, and in
13
association with RAOs believed sponsored almost simultaneous, serious intimidating
14
THREATS against Figas and his equipment, by Kyle Skillings in 2011, discussed above, Mathson
15 is believed to have been interrupted from personally attempting to vandalize, arson (and/or
16 study in the dark) the 85,000# contractors excavator parked only 20 inside that very gate.
17 Perhaps he was scouting the vulnerabilities of the excavator, planning or even beginning to
18 EXECUTE a vandalism and analyzing our then non-existent and also historically mostly
19 unnecessary (until NOW) human security measures (since enhanced) in advance for Skillings
20 and/or other unknown RAO employees now expected to do Mathsons mechanical dirty work
21 involving the slightly more sophisticated art of effective, meaningful equipment vandalism and
arson, as opposed to Mathsons specialty of fence vandalism. [The section was originally written in
22
2014, and has been updated several times especially in 2016 to March 2017, and overall it is
23
undoubtably redundant and repetitive but too late now to do a major revision couple days before
24
filing this.]
25
On the above 2012 night, Defendants could have intended to start-up Figas excavator to
26
do untold damages, such as knocking down Plaintiffs entire house in minutes, or arson, all of
27 which criminal acts would be trivial for a knowledgeable owner/operator to accomplish, which is
28 presumably the main reason why Figas justifiably very abruptly pulled his machine off the job,

125
leaving 75% of his planned and needed work unattempted, and when the work was IMPORTANT,
1
and he badly NEEDED the money to pay a large crew out of season.
2
Alternatively, that same night, Mathson could also have been in the act of vandalizing or
3
studying (to thoughtfully accomplish same in the future at an inconvenient time such as during
4
trial), Plaintiffs car, which Mathson was less than 2 away from when Plaintiff discovered
5
him, and from which he nearly RAN, at a super-fast (for him) 6-8 m/h limping walk. No how
6 are yous, nice evening for a walk, etc, just a quick panicked escape to avoid detection and
7 identification which miserably FAILED in the 500+Watt sodium vapor streetlight 30 away, which
8 he was trying to innocently run towards, making an easy, instant positive identification. No
9 words were spoken as Mathsons eyes met Remingtons, because the implications were very
10 SERIOUS, jarring and required thoughtful consideration, and STILL do.
11 Thus, no serious actual crime was witnessed that night, however a criminal attempted act
and crime in progress was definitelys prevented, accidentally by seconds. John Mathson and
12
Remington BOTH know that he came very close to arrest and perhaps JAIL, or worse, that
13
night. Had Remington come out one minute later or not at all, there would be much more to
14
the story now. After that incident, Mathson did not show himself at any hearing for at least 2-3
15
years.
16 The Skillings intimidation of Figas complained-of in the Seventh Cause of Action, and
17 elsewhere, occurred twice, at least one of which was a day or two AFTER that encounter, which
18 Plaintiff did NOT mention to Figas, who was independently scared-off by Skillings.
19 This above-referenced 2012 intimidation, threats, attempted vandalism or arson, and
20 strongly inferred, thinly disguised, unlawful, pretrial DISSUASION of witnesses and contractors
21 by Skillings and assisted by, aided by and in combination with John Mathsons continuous
22 surveillance, harassment, multiple fence vandalisms and above-described inferred trespass on
November 23, 2012 (above), at a minimum, (especially in combination with his other 30+ criminal
23
vandalism acts against plaintiffs property) is not a mere, minor wobbler under California law, but
24
could easily arise to felony actions under the circumstances of the additional Multiple ACTUAL
25
acts of and threats of vandalism and/or destruction of Figas under-insured huge excavator in
26
November 2012. NONE of this is funny in any respect, and in fact is deadly serious, and at some
27 point will be taken seriously by law enforcement upon gathering more actual evidence of these
28 acts.

126
NEITHER MATHSON NOR SKILLINGS ARE TO BE TRIFLED WITH AS
1
MATHSON IS A KNOWN SERIAL VANDAL (AND HENCE AN ACTIVE CRIMINAL
2
CONSTANTLY LURKING AROUND PLAINTIFFS PROPERTY PERIMETER) AND
3
DEFENDANTS INTIMIDATOR IN CHIEF SKILLINGS IS ALSO SUSPECTED OF BEING,
4
AND ALLEGED TO BE AN EXPERIENCED, AND PERHAPS CONVICTED CRIMINAL,
5 AND BOTH ARE CLEARLY NOW VERY DANGEROUS TO PLAINTIFF, ALL HIS
6 PROPERTY AND THAT OF HIS FRIENDS AND CONTRACTORS, requiring mitigating steps,
7 including, but not limited to those costly steps and advance defensive, anticipatory preparations
8 partially revealed below, as costly, required additional DAMAGES due, for needing to take
9 unprecedented precautions, based on real actions, real vandalism and REAL threats and
10 surveillance, not paranoid delusions or fantasy. [Written in a 2014 amended complaint, this and the
previous several pages turned out to be very prophetic in retrospect].
11
Finally, the aforementioned additional NEW slide damages, discussed above, have caused
12
mitigation response costs, serious valuable, costly soil losses, requiring hand replacement with
13
buckets from hundreds of steep feet away and above, and plant damages of several thousand
14
dollars, according to proofs at trial.
15
As a result of the above, and similar acts, and pursuant to multiple case authority, Plaintiff
16
respectfully requests that the Court and jury award significant damages for emotional distress, as
17 permitted by statute for trespass, (which should include those incurred from Mathsons trained deer
18 army) and which would additionally be available for Defendants interference with Remingtons
19 specific property right to use his substantial land area adjacent to Mathson and below the dump for
20 pristine redwood and fall-color related gardens, and for pathways across said gardens, compatible
21 with his multi-acre adjacent gardens, which use has been totally abrogated and eliminated by
Defendants pollution, which damages will continue until remediation. Interference with Plaintiffs
22
multiple-species agricultural operations of all sorts also warrants emotional and/or treble
23
damages under California Trespass authorities, as well as under federal RICO statutes.
24
ADDITIONALLY, Gans and Plotz have already filed blatantly frivolous Malicious
25
Prosecution charges against Remington in DR140426 related to the Federal case, presently stayed,
26
after the SAME charges were dismissed by Judge Reinholtsen in DR080678.
27 Remington demonstrated OBVIOUS probable cause in the 2009 federal case when attorney
28 Hans Herb assisted in the filing and reviewed all allegations in BOTH cases active then and joined-
in.
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The Magistrate also ruled in DETAIL on said case in 2009, allowing it to go forward on the
1
facts as then known, which would have easily prevailed eventually, but for Remingtons disclosure
2
error.
3
9. The definitions at 18 USC 1515 (a) (1,3 & 6) and (b), apply to John Mathson
4
concerning his making false statements, omitting information, intentionally concealing facts
5 and destroying material evidence; and also 18 USC 1952 applies, barring interstate travel
6 with racketeering or gambling income, BOTH applicable here, as discussed.
7 The Mathsons have owned the same big ugly, dilapidated old travel trailer, which dominates
8 their backyard for about 35 years. Although more discovery will be done on this issue, Remington
9 presumes that the Mathsons' frequent vacations North involved going to Oregon and if that is the
10 case then their illicit, untaxed and corrupt Enterprise profits from the last several years has been
used in impermissible, predicate act of violating interstate travel. Based on Remingtons many years
11
of observations, he is highly confident that the Mathsons have used that ugly and offensive travel
12
trailer to go out of state over the last few years, and that to do so would necessarily have involved
13
using some of the more than $100,000 of unlawful profits the Mathsons made in 1998 and
14
subsequently, by not paying major income tax justly due in 1998 for their huge Real estate
15 appreciation; by not paying rent or properly compensating Remington in any way for their
16 unlawful, non-permission use of, but nevertheless their actual very heavy use of a large portion of
17 Remingtons adjacent land.
18 A large amount of very detailed discovery will be done in this area in this case and also in the
19 several related State cases to enhance this potentially very serious area which is also coupled with
20 major felony federal, county and state tax evasion.
10. 18 USC 1956. Money laundering uses are illegal, and BOTH Mathsons', especially John
21
Mathson in this RICO enterprise are very guilty of this crime, as just discussed at #9 above.
22
a. In addition to the illicit and unreported income discussed at number nine above, related to
23
the Mathsons' vast windfall doubling of their usable back yard space, thanks to RAOs massive
24
4000+ cubic yard illegal residential waste dump which today exists like a World War II time bomb
25 underneath Mathsons meticulously manicured lawns neatly planted on top thereof, the Mathsons
26 have engaged in many other types of money-laundering.
27 Since virtually every development activity which the Mathsons do is somewhat or very
28 illegal, all of their illegitimate income derives from money-laundered sources, in some respect.

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b. For example, the Mathsons are known to deal in various forms of as yet partially
1
undiscovered common drugs or other controlled substances, in addition to the illegal and
2
uncompensated use of Remingtons adjacent land complained of at number nine (#9) above.
3
c. Another type of laundered money was received by the Mathsons around June 2016, when
4
Gans successfully extorted $20,000 cash from Farmers Insurance, which is discussed above, and
5 simply put was when Farmers Mazie Klein decided that paying-out $20,000 dollars was definitely
6 the lesser of the evils (or RISK) for them. No guilt was conceded by anyone, however Farmers
7 made the obviously in retrospect, wise business decision to pay a mere $20,000 to avoid being
8 extorted and slowly bled for another $100,000-500,000, or more.
9 Meanwhile, arguably that $20,000 just received by the Mathsons' was not justly earned and
10 was clearly the product of this overall extortion racket enterprise promulgated by Gans and now
sued here under RICO. In fact that $20,000 was the first major prize won by Gans RICO
11
enterprise, in mustve been a source of great pride. Gans visual nuisance, irritation, super-trivial
12
trespass and pollution suit against Remington was very frivolous from the start, a real laugher all
13
along (objectively), and eventually Gans ill-gotten $20,000 dollars in this improper extortion/
14
bribery/settlement is about what defendants probably spent prosecuting that ridiculous DR080669
15 case to that point.
16 Obviously, there are two sides to that issue, and well get another side from Gans no doubt, but
17 meanwhile this odd, minor incident is only 1/1000th of Remingtons RICO case, but it is raised
18 nevertheless for court consideration whether characterized as a settlement, impermissible mention
19 of insurance, our something else. Remington believes that the $20,000 was also corruptly
20 extorted from Farmers, but it could also be construed as bribery, which is how Remington might
look at it.
21
22 Essentially, as explained with more clarity and detail above, Gans bribed Farmers to get out of
23 the case, to force Harvey Roberts to stop helping Remington, and as a result to tremendously
24 weaken Remingtons overall trial offensive contamination cases. All of that worked great for both
25 insurance companies but was very detrimental to Remingtons overall interest here.
26 11. 18 USC 1957. Specifically bars property sales and other purchases with laundered
27 dirty money. The Mathsons' specifically violated this federal law and are now subject to heavy
28 fines and imprisonment, based on their illicit 1999 major home renovations and expansions which
used exclusively laundered money from there illegal 1998 residential Class One dump site. The
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1 Mathsons and RAO made huge unjust profits from that criminal dump site, which the RICO
2 enterprise is now desperately trying to conceal and cover-up.
3 State discovery and trials have begun to expose part of the Mathsons $20-$50,000 1999 home
4 expansion and construction of a gigantic 5-10 car garage, that practically touches Remingtons land.
5 The 2016 SOL trial featured many photographs of that project but this case will involve the
6 financial details and prove that project was built with unjust riches and laundered money from
7 the hundreds of thousands of dollars of illegal payments by many illicit Humboldt County truckers
8 (such as Joe Costas major trucking firm). Said truckers violated dozens of hauling, dumping and
9 permanent disposal laws by dumping every type of local hazardous and contaminated material in
10 the Mathsons' dump for which Mathson and RAO were well-paid.
11 Arguably, under most applicable RICO law, the money the Mathsons spent in 1999 is barred by
12 the applicable SOLs and therefore their 1999 massive home expansions are not predicate acts here
13 in 2012-16. However, The Mathsons' kept spending substantial money on their yard every year
14 throughout the relevant periods.
15 They are constantly using that old laundered money for expansions, gigantic new fences, riding
16 lawnmowers, remodeling, re-seeding, irrigation, huge garden expansions, many new lawn buildings
17 and for making their basic mortgage payments into the relevant 2012-2016 period.
18 Discovery will reveal the exact financial details, however to the extent that the Mathsons' did
19 the above, and used old or new racketeering enterprises money to purchase or finance real estate
20 and then to payoff whatever loans they prove to have now, they massively still violated RICO and
21 specifically the above 1957, as a predicate act.
22 This is not a predicate act that is required here, but just another smaller predicate act, perhaps
23 Number 25 or 30, nevertheless. We have a lot more detail on all of this now, however in the
24 interests of some semblance of brevity, Remington will save it for later forums, where it can all be
25 12. 18 USC 1961-4, et seq. Additional money laundering statutes barring illegal profits from
26 being invested in businesses. This is an area which will be emphasized during future discovery and
27 Remington has numerous questions. For example, did the Mathsons' invest in any of RAOs major
28 Real estate developments in subdivisions along Walnut and throughout Cutten?

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1 Given the fact that the Mathsons' have been living on and operating from more than $100,000
2 of illegal and unjust profits from the late 1990s, have they purchased anything with that money or
3 made any kind of investment and anything with a real estate or not with their illicit racketeering
4 gains? Have the Mathsons ever purchased anything out of state on the internet from Amazon, EBay,
5 Walmart or anyone?
6 The Mathsons are living substantially on unjustly gained funds from the last 20 years (and
7 including the $20,000, above, from 2016), and the remnants of those corruptly gain funds both past
8 and present have all been co-mingled with their Social Security, disability and other unjust riches
9 dollars. Cumulatively, once the initial hurdle of a RICO racketeering cover-up enterprise is
10 successfully crossed and established, the rest of these more minor predicate acts could snowball and
11 it will ultimately be up to a DA and/or a jury to sort all this out, not Remington.
12 13. 49 USC 5101, et seq, John Mathson has improperly and unsafely hauled hazardous wastes
13 without proper permitting and placarding from his illicit, criminal evidence gathering and
14 spoliation at the dump to wherever he has taken it and disposed of it, assuming that its not
15 just still stored behind his house somewhere, which of course well look for imminently.
16 During 2012-16, John Mathson has been seen on cameras, or known to have tampered with
17 crucial material incriminating evidence on the dumpsites on both properties. Many still photos and
18 videos confirm that. It is unlawful to remove evidence from crime scene after you committed a
19 crime, so that the police investigating it dont find it, or if a jury visits the site or a photographer
20 shoot said site later it looks like nothing ever happened there.
21 Here, the serious damage goes 10 to about 18 feet deep and Mathsons removing a few items on
22 the surface does not do any significant cleanup. Most of us have seen the Servpro national
23 commercials of the major flooding or water disaster with mold and infections. If youre trying to
24 collect money from an insurance company or jury you take before pictures of the accident or
25 disaster and perhaps after pictures AFTER Servpro, etc. has done there $30,000 or so of cleanup
26 work. Here, John Mathson acts improperly and illicitly like Servpro and then Gans is corruptly
27 presenting only the after photos (like it never happened) or leading a site walk through and
28 claiming that the after situation is really the Before situation, which again just means that Gans
mischaracterizes the entire incident of contamination, and falsely says that it never happened,
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1 despite the fact that the contamination is 15-feet deep. That analogy indicates the serious material
2 mischaracterizations which Gans regularly employs, however, this case is actually different and its
3 not about cosmetic damage at all, but about deep serious structural damage. Servpro specializes in
4 superficial surface or water damage but, HERE we really have a very deep termite-like infestation
5 10-20 feet deep, with billions and billions of termites in effect. Again analogously, John Mathson is
6 in effect removing a few hundred surface termites and concealing their few small tunnel entrances
7 and exits with redwood needles and then Gans is arguing to nave jurors who dont necessarily
8 really give a damn, that there are no termites here at all, because Mathson effectively concealed all
9 evidence of termites at the ground surface. Having earlier photos that show the entirely accurate
10 truthful situation, would help, however here without an excavator that can show solid hazardous
11 debris 15-20 feet deep it is hard to prove what is here. In our analogy, that would be massive termite
12 tunnels and solid, serious structural damage more than 15-feet deep and over a large area that has
13 been cosmetically altered on the surface to conceal that. Our experts and our borings and
14 engineering analysis have proven all parameters of the dumps depth and lateral extent, however
15 Gans experts and Mathsons' major, felonious evidence spoliation have fraudulently concealed the
16 extent (volume) and severity of the dumps contamination and attempted to minimize and grossly
17 misrepresent it. We have plenty of experts, tests, charts and analyses to prove what is really here,
18 however Gans and his enterprise have now made that an expensive month-long trial process to
19 present.
20 Specifically, John Mathson has been seen frequently on surveillance videos removing
21 individual deadly poisonous asbestos pipes and Chrysotile sheets to presumably put in his
22 residential garbage cans, unless he can produce at his next deposition several dump receipts for
23 early 2016 were he bagged, identified and declared, properly placarded his hazardous loads to
24 prove that he properly disposed of that asbestos somewhere, which he obviously did not do. Such
25 proof of compliance from the enterprise is clearly not available, Because Mathson, Gans and the
26 enterprise never do the right thing, which here would be to properly dispose of any hazardous
27 waste which they illegally gathered. But, just like we hardly expect the Godfather of a mafia
28 organization to get a permit to haul and dispose of a murdered body in the river, Gans and his
enterprise dont get permits for their is illegal activity either.
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1 14. 42 USC 1983, Miscellaneous actionable deprivations of Remingtons rights by John
2 Mathson personally. John Mathson has deprived Remington and the Burl Tree of its civil rights for
3 many years, as complained herein.
4 As argued above under Gans set number 16, John and Joy Mathson radically infringed upon
5 and erased all of Remingtons rights to privacy and quiet enjoyment of his property when they
6 harassed Remington and the Burl Tree with continuous complaints to all regulatory authorities in
7 Humboldt County in 2012-16, and prior to that.
8 Similar to an echo, the actions that John and Joy Mathson started with their scores of
9 complaints to state, county and federal authorities, e.g. the County Health Department, planning
10 department, Fish and Game, fire, air quality, building inspections, IRS, EPA, HCSD, etc. all
11 continue to haunt and/or harass Remington many years later. Once on the radar of most of these
12 agencies it is hard to get off it in many cases. [See color charts pages 11-12 in the main complaint
13 for details about this].
14 Other 1983 violations cited and discussed under Gans, who gave the orders and who also
15 made or issued the specific complaints in many cases include, without limitation: The file room
16 saboteur, who is either related to the Mathsons organization or directly to the Mitchell firm; the
17 serial vandalisms of Remingtons fences and the extensive neighborhood slander promulgated by
18 both Mathsons, to all in the Westgate community who have the time to walk their dogs in front of
19 the Mathsons and stop to talk. In addition to Remingtons subjective due process rights, his rights to
20 good personal health have also been bravely adversely affected by defendants.
21 Remingtons time and health are directly proportional to the Burl Trees sales and prosperity in
22 interstate commerce. Just in the relevant 2012-16 period alone, Burl Tree sales are down
23 approximately $80,000 per year from prior comparable periods of commerce. In 2013 alone
24 Remington also lost approximately $29,000 of scrap iron and equipment sales alone to Oregon,
25 which may never be fully recoverable.
26 Remington has also been made very sick since 2012 by (per trial proofs) Mathsons
27 contaminants, especially by the asbestos fibers which cause uncontrollable coughing in the vicinity
28 of the dump and from the coliform bacteria and derivatives that have reduced Remingtons strength

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1 and ability to cut and/or sell burls or to make plaques for the US Justice Department, Remingtons
2 best customer today.
3 See below and see the FAC in this case for more allegations and detailed evidentiary proofs of
4 these 1983 allegations. Mathson has done many other specific individual criminal acts here that
5 are not all included in this document, e.g., especially objectionable and dangerous is Mathsons'
6 randomly shooting 4-foot long metal pointed arrows into Remingtons yard when his
7 grandkids are walking around fearfully attempting to pick a few roses, before they get eaten by a
8 bear or rammed by a panicked buck. Those criminal acts are very damaging, especially dangerous
9 and not merely an extortive act, but causes many types of general damages in many family
10 members. Someone could get killed that way, and proofs of what we know about the arrows and
11 their origin will be saved for trial. Quite possibly, the RICO gang members only shoot arrows over
12 when they are drunk or high.
13 15. 42 USC 102. For many years, the Mathsons' have been seen selling, using and
14 dealing in various controlled substances, here on Westgate Drive, including amphetamines and
15 marijuana, among others. Anecdotally, some of Remingtons neighbors have also complained about
16 the apparent late night serious business dealings, noise and confusion at times and the odors
17 inferring a possible amphetamine manufacturing lab emanating from that northerly direction, which
18 encompasses both the Mathsons and Kishpaughs properties and controlled areas. The Mathsons
19 land is the most likely since their property is10 times bigger than Kishpaughs and the former also
20 has 3-4 mysterious sheds scattered around their property in the woods which Remington has never
21 investigated or determined their purpose, yet. The problem was especially noticeable and acute
22 during the early to mid 2000s when the owner of MDs tree service lived directly across the street
23 from the Mathsons' and was a major negative influence on that area. There was even pedophilia
24 rumored to be emanating from that MD/Mathson vicinity. MD no longer lives across from the
25 Mathsons, which is an upgrade, but which year he left is not presently determined.
26 Remington has been too busy himself mostly (like NOW), to concern himself with what
27 Mathson does, however future discovery will focus heavily on this area of predicate acts, and the
28 numerous complaining, observant and interested neighbors, with kids, adjacent to Remington and
Mathson will be interviewed carefully as time permits.
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1 16. OTHER, such as 18 USC 1643-False declarations before a grand jury or court.
2 It should be noted, that this document is merely Remingtons initial RICO statement and
3 drastic additions and revisions are anticipated in the near-term. Due to the magnitude and
4 materiality of the fault statements and perjuries which defendants have committed in state court and
5 now must defend here in analogous and/or parallel proceedings, it is expected that many new
6 federal predicate acts, some not yet alleged or known, will be violated imminently, especially by
7 John Mathson. That will obviously necessitate a second and undoubtably a third, and possibly a
8 fourth RICO statement to keep these many thousands of facts up-to-date and accurate.
9 For example, under 1623 (c): An indictment or information for violation of the section
10 alleging that, in any proceedings before or ancillary to any court or grand jury of the United States,
11 the defendant under oath has knowingly made two or more Declaration which are inconsistent to
12 the degree that one of the is necessarily false, need not specify which declaration is false if:
13 (1) Each declaration was material to the point in question, and
14 (2) Each declaration was made within the period of the statute of limitations for the offense
15 charged under this section.
16 (3) In any prosecution under this section, the falsity of the declaration set forth in the
17 indictment or information shall be established sufficient for conviction by proof that the defendant
18 while under oath made irreconcilably contradictory declarations material to the point in question in
19 any proceeding before or ancillary to any court or grand jury. It shall be a defense to an indictment
20 or information made pursuant to the first sentence of this subsection that the defendant at the time
21 he made each declaration believes the declaration was true.
22 Without fully explaining this hypothetical with a lot more detail here, suffice it to say that
23 Mathson has now knowingly and intentionally perjured himself on 20-30 major issues in this
24 case and now going forward he and his ventriloquists voice and writer (the enterprises demonic
25 mastermind) will have to consistently back-up that perjury, which, as hypothesized above, it is
26 doubtful he or THEY will be able to do, seamlessly, consistently and FLAWLESSLY. Imprecise
27 recall which will quickly become intentional perjury may land them ALL in jail, if RICO law can
28 be properly applied and really works here. In any case, we will be attempting to break THEIR
perjury chains of lies, have plenty of time to DO SO, and expect to be able to meaningfully trip
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1 him up in front of a jury, indict him and at a minimum recover substantial treble damages from the
2 entire enterprise, under this section. If the DA wants to punish HIM further, thats up to them.
3 There is no doubt to Remington in December 2016 that future discovery, defendants sworn
4 defenses (if any are actually sworn which would be rare), detailed and complex Discovery and the
5 inevitable anticipated flurry of RICO rats frantically attempting to leave Gans sinking
6 enterprise ship, WILL lead to numerous new federal predicate acts, here. SOME, will presumably
7 be against many additional, as yet undiscovered members of this RICO enterprise, and also against
8 several rather obvious named defendants, who have gotten off very lightly here, so far, as compared
9 to what is anticipated in planned going forward. Additional federal predicate acts that are
10 discovered in discovery will undoubtedly subject them (present and additional enterprise members)
11 to fines and/or imprisonment, which differ under each statute violated, and therefore it would be
12 onerous and too cumulative to list under each individual statute all known or anticipated violations
13 or to fully list each present defendant with each known individual violation thereby, plus what is
14 likely, expected an almost certain to be discovered imminently, when discovery starts.
15
16 2. D. Rich Olson, President of RAO Construction and arguably the original creator of
17 all problems which Gans enterprise was established to correct, cover-up and to exonerate all realty
18 criminals involved here an initial 1998 contaminations of Mathsons' and Remingtons land.
19 Because Skillings has worked for Olson and RAO construction as an employee for
20 something like 30 years, he is mentioned in virtually every paragraph below, and therefore
21 the criminal predicate acts attributable to him are considered at this time to be inseparable
22 from those of Rich Olson. Because Olson has not really done anything yet in these cases, and
23 because Skillings is believed to be equal to or identical to (so far) in the RAO 2016 trial
24 appearances, it may now be inferred that anything Skillings does was known to Olson and quite
25 possibly ordered by him. That principle will be further tested during discovery to see what
26 variations are present. Specifically alleged acts and crimes by Skillings which are presently known
27 are additionally alleged separately in the following section of this statement and in several other
28 areas. In other words, substantial discovery is still needed to probe the RAO Co, Inc operation and
it is presently believed that many more of their employees will eventually be named as defendants,
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1 who today would merely be DOE defendants. Fortunately, the otherwise nebulous relationship
2 between RAO, Kluck, Mathson, Gans and the Mitchell firm, etc would be complex and difficult to
3 understand but for the clear RICO connections. Gans has handled and worked intimately with
4 Skillings for years and has also been seen to be in nearly daily communications with Kluck in the
5 courthouse corridors alone, hence the fact that Gans today works closely with the RAO defendants
6 can really only be understood in the context of a wider RICO conspiracy.
7 Richard Olson the owner of RAO construction is the original criminal here who in 1998
8 approached the Mathsons with a criminal scheme wherein they could all make big money, plus Joy
9 Manson could expand her lawns to compete with the big house to her south, owned by
10 Remington, who they admittedly greatly envied. Olsons identity and role as a Mathson contractor
11 was unknown until 2009-11 and his identity apart from Skillings and RAO Corporation, plus his
12 actual overall diabolical criminal role here and related illicit, unjust profit-making scheme was
13 not revealed until about 2014.
14 In 2014, Olson was first separated from the Mathsons and Gans as an independent player
15 and his insurer evidently hired Kluck to protect him, however so far neither Kluck nor Olson has
16 yet gotten significantly involved in any of these cases for reasons explained elsewhere.
17 Skillings has been a major witness in Gans illicit Mathson defense all along and Skillings
18 worked for Olson for 25 or more years. Olson was named a DOE defendant in DR 080678 and is an
19 important defendant in DR140426, currently stated and inactive.
20 Whether Kluck will now represent Skillings and Olson is presently unknown but very
21 crucial now, because if so, Kluck will automatically become involved in the RICO enterprise, and
22 implicated and complicit with Skillings and Gans corrupt perjury organized carefully rehearsed,
23 coached and executed in August 2016, which inferentially is all intended to ultimately cover-up
24 Mathsons and Olsons crimes in particular. Kluck was not observed in the court room in the 2016
25 trial, however whether he assisted Gans in coaching Skillings and in orchestrating the serial,
26 brilliantly coached and well-coordinated perjury among Gans five trial witnesses (including Joy
27 Mathson but excluding Pulley), has not yet been discovered, but will be shortly. As noted
28 elsewhere, in all probability Kluck is fully involved in the RICO racketeering conspiracys
leadership TODAY and has been for about two years. He keeps a low profile and defers to Gans
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1 and Plotz in all written documents, but hes always around their talking seriously and furtively to
2 Gans. Only a tiny bit more information will be needed to name him as one of the top five MOST
3 culpable RICO defendants.
4 In the state case, especially DR140426, Olson, RAO (and presumably Skillings), as alluded to
5 above in a March 2017 edit, are almost certainly known to be represented by Larry Kluck of
6 Matthews, et al, attorneys, although no direct evidence of that has been seen for more than a year,
7 and early representations made by Kluck while deceitfully avoiding what shouldve been a default
8 judgment for lack of any timely answers or any responses, were so unreliable as to be disregarded.
9 In that case no discovery has ensued, despite numerous attempts to do so since 2014. Discovery
10 there would be mostly interchangeable with discovery here, and therefore discovery in one case or
11 another is believed to be imminent.
12 In the state cases, Olson and RAO are the primary offenders and villains, however Skillings
13 has made his unpleasant presence known constantly in 2016 and is one of Gans Star witnesses
14 against Remington in the contamination cases, and WAS already in the August 2016 statute of
15 limitations trial.
16 Which attorney represents Skillings primarily in this federal case, is presently unknown, but
17 presumably it would be Kluck as part of the RAO defense; but, since Gans has also already
18 corruptly used Skillings extensively in 2016, and in the SOL trial already has written, scripted,
19 coached and supervised Skillings memorization of about an hour of already executed perjured
20 testimony, Gans must also now stay involved, making a complex and convoluted situation for
21 Kluck, no doubt. However, that is their problem. For Remington, thats great. How and whether
22 Kluck can now go through a solid two weeks of convoluted false testimony by all of Gans witnesses
23 and put that in terms of Remingtons testimony and depositions, will be of considerable interest. He
24 is an experienced professional, so maybe hell do it artfully in a few days, but at his age, it may take
25 longer and never be done properly. Therefore, it will no doubt be tempting for Kluck to just
26 exercise his intrinsic laziness and defer entirely to Gans leadership, corruption and RICO
27 enterprise leadership. The Kluck of 30-50 years ago would strike-out on his own and probably
28 never would have let Skillings get so involved with the RICO conspiracy, but now it would appear
to be too late, so as speculated above, it now would appear to be a near certainty that KLUCK is
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1 already in the RICO enterprise due to his own failings and dwindling energies, for the reasons
2 hinted at above, and can almost certainly expect to be named as a RICO defendant, probably before
3 the time of a FAC. In any event, whenever it becomes certain, and not just 90% certain.
4 Gans has woven a beautiful, complex, deceitful, inconsistent and unsustainable, totally
5 unstable testimonial structure for all of the enterprises witnesses that he has so far used, and since
6 they are now all part of the same enterprise, they can now attempt to figure-out what theyre going
7 to say and do. It is now impossible to get any of their witnesses testimony logically, correctly or
8 honestly at this point and Remington of course will be watching for every detail of testimony now
9 by Skillings in particular and then by Olson, who is crucial in these cases. The anticipated astute
10 court in this case should also soon be able to follow Gans and Klucks future now NEEDED deceit,
11 deception and required additional perjury (to consistently support their major and extended August
12 2016 perjurious trial testimony) which now must be maintained in an attempt to corroborate it
13 consistently with hours of transcribed state trial perjury. Therefore, as explained in some detail
14 above, it now appears to be essential and out of Klucks control as to whether he will or must join
15 hands RICO enterprise, because to keep his RAO clients testimony consistent with the corrupt and
16 perjured 2016 state trial testimony, he literally has no choice today, except to acknowledge that
17 Skillings is a perjurer and should be punished for it.
18 Remington alleges and asserts that it will now NOT be possible for Gans or Kluck to maintain
19 any type of integrity or honest posture on any issue, in this case, and therefore they either wont
20 defend against this RICO action, or just as likely they will elect not to participate in ANY of this
21 case at all, especially if there initial perfunctory motions to dismiss fail. Theres been WAY too
22 much perjury now in all of 2016, too many inconsistencies and Gans offending witnesses are not
23 smart enough, young, quick or deceptive enough with good enough memories, and are also not
24 motivated enough to maintain their lies and deceptions for the next few years, as needed, just to
25 protect Gans, and now several other attorneys, essentially. Remington believes they dont get
26 paid enough to do that and therefore ultimately they wont do it, but probably only after they have
27 buried themselves in hundreds of more unsustainable lies. Remington is expecting and counting on
28 the latter.

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1 This RICO case however places Gans in that primary bad guy role, which involves the
2 cover-up and all the related RICO objectives named above. What Olson and Klucks exact roles in
3 this RICO enterprise today are, as not yet fully known. Thorough discovery is needed here since
4 Discovery in DR140426 was successfully blocked and then substantially stayed in the state courts
5 for almost 2 years. [Rather obviously some of this very long statement written over six months is
6 inconsistent with, or in any event legs for behind what has been understood and discovered
7 subsequently and added here and there in the March 2017 edits. Time does not now permit the total
8 rewrite, which would be useful, but which as explained will be done in due course, after the initial
9 case has been filed].
10 Because Gans leads this RICO racketeering enterprise for all defendants right now, and since
11 Kluck has not participated much, if at all, in hearings or motion oppositions for two years,
12 Remington sends all his case documents involving RAO to Gans who copies everything, thousands
13 of pages, and forwards everything to Kluck and Olson. That practice obviously facilitates Gans
14 control of the enterprise as he can then skew and comment on anything Remington does in terms of
15 the RICO Enterprises objectives, any obviously Gans does so. Evidence of that collusion is beyond
16 the scope here, however Remington has had some personal contact with Kluck at various hearings,
17 and saw him very frequently during March-August 2016 in court room corridor conferences with
18 Gans, undoubtedly about Remington in this case, judging from their furtive looks at Remington,
19 whenever he looked at them. Additionally, Kluck has spoken to Remington 5-6 times, including at
20 least twice in 2016, which actually arose to the level of a cited predicate act in one case. Kluck
21 constantly attempts to engage Remington in conversation to evaluate his anxiety level and to try to
22 determine Remingtons resolve, motivation and whether he expects to win these cases and/or if he
23 might lose, what then would Remingtons reaction be to that? In other words, is Remington likely
24 to seriously and doggedly pursue Olson and RAO, if he experiences a few legal setbacks as have
25 occurred recently, or is he likely to quickly fade, collapse and go back into retirement?
26 Essentially, Kluck frequently attempts to determine Remingtons stability, sustainability and
27 overall competence under litigation pressures, all of which scored rather high in state court, given
28 Remingtons age, experience and with the rest of consecutive early-morning appearances for
approximately 110+ consecutive days of three-hour substantively intense hearings daily with Judge
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1 Reinholtsen, requiring 3-20 hours of preparation each, typically. Incidentally, Remington held-up
2 just fine under that legal pressure, without missing a day (for any reason), a deadline, a case
3 citation, or ever even being late, despite an old car with a weak battery and bald tires, and no cell
4 phone in the event of an emergency.
5 In fact, those consecutive intense pretrial hearings where more than 200 Motions in Limine,
6 and a thousand items of chart, photographic and business record evidence were considered carefully
7 were FUN. There, actual facts, case law and actual True Evidence and exhibits were considered on
8 their merits for inclusion or exclusion, as opposed to dealing solely with Gans mostly August 2016
9 created nebulous lies and blatant, serial perjury, which was hard to refute at the August 2016 trial,
10 when Gans first presented it with prejudicial and impermissible surprise in his opening statement.
11 As of 2017, Remington does not recall ever having met Olson, and therefore does not know
12 him personally, but is aware of his aggressive and scurrilous reputation, and drives by his extensive
13 residential development along Walnut Drive and his now small equipment yard daily, without ever
14 seeing any evidence of actual business activity. The inference being that perhaps he doesnt really
15 have an actual ongoing present-day business and it is just some sort of tax write off.
16 Presently, Remington alleges that Mathson and Olson are each responsible for a minimum of
17 $1 million of damages each. That can be calculated in many ways and involves about 50 different
18 types of damages which if in the several hundred thousand dollar range, and then multiplied times
19 three from a favorable RICO verdict, that would be another method of compensating Remington for
20 approximately all detriment proximately caused thereby, said defendants Olson and Mathson.
21 On the other hand, if these cases go on for too many more litigatory years Remington may
22 just die slowly from the inhaled friable asbestos and Chrysotile fibers in the air here derived from
23 the hazardous waste dump, plus its toxic vapors and carcinogenic dusts, robust fecal derived
24 bacteria and viral mutations, and new anti-genetic variations, apparently prevalent below the
25 dumpsites, on Remingtons land.
26 1. 18 USC 1951, Hobbs Act, EXTORTION. RAO deliberately and believably causing FEAR in
27 Remington and his witnesses, especially Figas through RAOs employee Skillings in this case.
28 When discovery begins, it is expected that RAO and Olson had other employees and contract agents
involved in the Mathson-Remington illegal dumping projects, such as Joe Costa who was a known
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1 and involved, illicit-reputation, local trucking company in the 1990s which Gans acknowledged at a
2 deposition, had did some of the illegal hauling on this project. Remington presently believes that
3 Olson colluded and schemed with John Mathson, and his local gang of drinking buddies, drug
4 users, probable thieves (see Mickey Kishpaugh) and other misanthropes, including, without
5 limitation: Both Kishpaughs, Evans, Hilfiker, Gary Costa, BOTH Mathsons, etc., beginning in
6 about 1998, to lay the initial foundation for, if not to actually to start this massive present RICO
7 criminal conspiracy. Although arguably somewhat nebulous, Remington herein asserts that the
8 consistent and intelligently interlocking PATTERN of systematically related predicate acts required
9 under 1961, of the RICO act, to make a cognizable claim, as explained herein to reach the
10 Enterprises objectives, did not really begin in a legal sense under the Supreme Court law
11 precedents, until late 2012- and into May 2013.
12 As explained and discussed in this federal complaint and in Remingtons state amended
13 complaints, defendants original plan to establish an illegal class one hazardous waste dump only
14 10-minutes away from the thousands of cubic yards of hazardous hydrocarbon saturated soils, gas
15 station underground remediated accessories, Asbestos and/or radioactive or biological waste
16 materials was demonically quite Brilliant. It was also a well-executed, very effective, entirely
17 feloniously illegal excavation and trucking operation, which accomplished the rather formidable
18 task of burying nearly 1000 yd. of hazardous and related adverse debris on Remingtons land in a
19 few months. As explained in the 2016 SOL trial, the dump area on Remingtons land sloping away
20 from Mathsons backyard, was unnoticeable from Remingtons property as it was fully screened
21 from Remingtons view buy numerous dense Redwood trees and branches beginning at ground
22 level. Remington was also virtually never there in full or usable daylight, so he never would have
23 seen defendants dumping and disposal activities even if they had been not fully screened from
24 view by a dense redwood forest. However, in fact, Remington was not even ever there during
25 defendants project, never paid attention to what Mathson was doing over there, had no
26 knowledge that the defendants were doing a massive illegal dumping project until at least 2006, and
27 ever spoke to Mathson about any projects going on there in 1998 or until much later. All of those
28 true facts were fully set forth in the two-week trial transcript, however Gans successfully deceived
the jury, who never really seriously considered Remingtons position it appears. As fully and
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1 painfully explained in detail during 2016, Remington was the sole employee at a major retail store
2 which was open until dark during the summer, seven days per week and was not doing anything at
3 the Westgate property except moving is gigantic inventory for many months after the property at
4 3527 S. Broadway was sold the Flying J gas station as part of a federal case settlement, wherein
5 said gas station severely contaminated all groundwater underneath Remingtons property and much
6 of the soil from their massively leaking underground storage tanks over about 40 years.
7 As alleged at length in the state amended complaint, RAO and Olson benefited the most from
8 the vast unjust riches generated by this project. Said project being the RAO/Mathson illegal
9 dumping and disposal project fully described in the contamination portion of this lawsuit and again
10 outlined in the couple pages above, and somewhat below.
11 This vast Olson inspired and built illegal residential hazardous waste dump begun in 1998 is
12 actually not directly involved here in this case. It is not cited as a predicate act in this civil RICO
13 suit and arguably would be exempted by the statutes of limitations, even IF RAOs initial illegal
14 dumping and disposal could have been characterized as a federal crime, which it likely is not. It is
15 not listed under 1961 predicate acts, for example, it is certainly not needed to provide a second or
16 even a 10th predicate act, and therefore it is merely discussed and cited here as background for
17 perspective on the entire situation and in particular Rich Olsons role therein. Additionally, the
18 numerous environmental allegations cited herein previously for eight years in the State complaints,
19 fully covers RAOs massive criminal dumping schemes in the late 1990s. Since, obviously Olson's
20 initial 1998 dumping scheme and burial on Remingtons property was about as illegal as a project
21 can get, it does seem only just now that Olson may have to pay the price under federal fining and
22 imprisonment statues for his original 1998 highly profitable criminal dumping transgressions,
23 which are not even listed here as a predicate act here. 10 years from now when all discovery is
24 completed in this case, it also seems probable that additional criminal charges maybe brought
25 against Olson and RAO, that are not RICO related, but which may be serious enough criminally, to
26 not have any statute of limitations.
27 As explained herein, defendants 1998 crimes were huge and many-faceted and this present
28 RICO racketeering enterprise was therefore established gradually over quite a few years to
originally protect the Mathsons criminally and civilly, and then by 2015-16, Kluck sought
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1 further free intellectual, cost and legal brain-power type protection from Gans RICO
2 enterprise from the gradual discoveries made about the dump by many experts, most of which
3 were made in 2009-12 by various scientific testers from both sides. It took several more years to
4 determine RAO and Olsons criminal involvement here, but it is only rather recently that they
5 should be considered at least equal (or more so) defendants with the Mathsons and the others
6 named herein.
7 By 2012, sufficient scientific information had been discovered for Gans, Allied and RAO to
8 see that they had a big problem here, until Remington could be driven away or silenced some other
9 way, which they have been working full-time on for the last two years as explained throughout.
10 Now, today, Remington may have a big problem if Gans and defendants decide that they want to
11 silence him still. That is one reason why John Mathson and the Westgate gang of extort hers keep
12 applying not-so-subtle pressure to Remingtons gate and security fences, with which he is
13 associated every day and usually in the darkness. As explained above, the enterprise re-instituted a
14 continuous series of concerning intimidating acts from March 4-7, 2017 as of this writing, which
15 has not yet stopped, just to remind Remington that they are still there watching him every day, 24-
16 7 and bush-whacking him at his dark gates as he leaves every night almost like clockwork, is still
17 a viable option for them, something RICO enterprise thinks about a lot, and therefore that is a good
18 reason for Remington to fear for his life for safety, and therefore a REALLY good reason to
19 capitulate to the enterprise. In other words, almost every day the RICO enterprise attempts to make
20 Remington an offer that he cannot reasonably or prudently refuse, however, Remington being too
21 stubborn and bullheaded for his own good no doubt, has done exactly that, REFUSED. How
22 serious a penalty Remington will now pay for that refusal remains to be seen, as of 3/7/17.
23 Remington will explain all this to the criminal authorities, actually within 10 days of today it
24 would appear, and give them all of these relevant documents and sworn statements herein or the
25 several thousand pages of same from the prior 10-year litigatory record, but whether that will be
26 sufficient to preserve Remingtons life, in addition to his major security grades, self-protection
27 measures and related technological improvements already effectuated, remains in question.
28 Rich Olsons and RAOs first known significant predicate act on behalf of this RICO
racketeering enterprise was the fully documented extortion of Bob Figas, which was primarily
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1 executed by Kyle Skillings, over a period of 4-5 months, but eventually the depositions are
2 expected to show that Olson himself also participated directly, which is based on the present
3 witness statements and surveillance information. Gans was masterminding the syndicate by this
4 time, and it is presently unknown whether Olson had a lawyer yet or was just free-lancing on his
5 own in his absolute understanding and belief that Figas, and obviously also Remington, were a huge
6 threat to many of the enterprises members staying out of prison. Skillings worked for RAO in
7 2012-13, apparently since approximately 1992, and still does today. Therefore, he is and was a
8 long-time direct agent of Olson and also is and has been an ostensible agent of the Mathsons' who
9 have been close friends with Skillings for at least 20 years, and may have paid Skillings money in
10 the past, or vice versa.
11 During the 2016 SOL trial, Skillings under oath began setting-up an obviously false and
12 untenable scenario that he was merely an independent contractor working under-the-table for
13 Mathson in 1998, on the side and just as a friend, inferentially free and for no pay. He attempted
14 to portray that he just helped his friends the Mathsons out on evenings and weekends, as a favor
15 to them, and attempted to pretend that there were no huge expenses involved in maintaining
16 gigantic construction equipment involved with the 400- dump truck loads of imported hazardous
17 materials of non-native materials and contaminated wastes. On a gigantic illegal project where no
18 detailed time records or expenses may have been kept for obvious reasons, including to avoid
19 criminal culpability, again it may be difficult to easily prove some of the patently obvious facts.
20 Skillings is obviously as tough, mean and mercenary as they come, and clearly is not the type that
21 does any work out of charity or kindness. The fact that he did not charge Mathson anything to
22 come-over on weekends or evenings to smooth-out their criminally dumped hazardous wastes and
23 related spoils on Mathsons land merely indicates that RAO was extremely concerned about any
24 of it remaining in sight or smell for more than a few hours and tried to conceal their crime
25 every day. Skillings was obviously very highly paid by RAO for his efforts in that regard, and
26 Skillings perjuries in that regard will be rather easily proven with a detailed accounting of what
27 money Skillings was paid in 1998, what his hourly rates and deductions were, plus all of the related
28 analysis which Remington is more than competent to provide having employed thousands of
workers with every possible method of pay possible, including all required deductions in most
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1 cases. Therefore discovery will include a complex analysis of all pay records to all RAO employees
2 for many years.
3 The problem with some of that obviously false testimony and BS is that Remington knows
4 better personally and is and WAS a formidable expert in ALL ASPECTS AND ISSUES in this area.
5 Remington was in the exact same business as OLSON and RAO applicable to this lawsuit,
6 himself for more than 30 years, and understands very personally and very intimately the cost of
7 maintaining a few semi-trucks, semi-end-dumps, excavation tractors and gigantic loaders for many
8 months on a remote project, and those costs are not free, and they are not dismissively inexpensive.
9 RAO, or Skillings doing his work on the side as a favor (if he were to be believed, which he is not,
10 because hes a lying perjurer) would have had costs between $100,000-150,000 at a minimum on
11 that Mathsons' project and Skillings did not have that kind of money personally, then or now, to
12 give as a gift, to his wonderful, best friends the Mathsons. Neither did Olson, who was not even
13 friends with the Mathsons, (nor was Skillings before this massive criminal project started) and
14 clearly was not interested in giving anybody a $150,000 gift, except for himself, while he was
15 making at least a million dollars of illegal and unjust profits. Obviously this was a major corrupt
16 business undertaking with RAO's incurring the expenses and Skillings working as an employee, and
17 future sworn testimony will confirm that. Obviously, Olson and Skillings have had the most to lose
18 here at least up until recently. Now however, in 2016-17, Gans and John Mathson would appear to
19 have the most to lose and fear here, and the RAO faction would be next, including probable RAO
20 employees that we have not even yet heard about. RAOs vast criminal projects during the 1990s
21 would have made the present RICO enterprise very proud, however that illegal project fully
22 predated todays complains of RICO enterprise. The one may have somewhat led to the other,
23 however they are legally independent and obviously almost 100% unrelated, although a complex
24 philosophical treatise could be no doubt constructed around what little connections there are, and if
25 this case gets to the Ninth Circuit or beyond, someone will probably do just that, possibly
26 Remington as he was peripherally involved in both time periods, although in extremely different
27 ways and degrees of intentionality by defendants
28 What is clear now from Skillings perjured testimony in August 2016, and before Olson has said
anything on the record, we can expect almost solid falsification, mischaracterizations and probably
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1 sworn lies from all RAO witnesses. Therefore, in view of those facts, all imminent incisive written
2 discovery in this case, documents, Depositions and the proper sequence of interrogating the right
3 accessory witnesses in the right, logical order will now be considered carefully, in advance. After
4 cross-examining Skillings for about 40 minutes, it is clear that he is one of the organizations
5 weakest links, (aside from the Mathsons), intellectually, morally and as regards to telling the truth.
6 On the other hand, he is among the four top enterprises leaders and criminal offenders, and
7 although Skilling is merely a soldier like Luca Brassi in The Godfather film, Skillings is clearly a
8 formidable and very dangerous soldier, just like Brassi was, as explained, feared and attested to
9 above and below.
10 Skillings lives less than 2 miles from both of Remingtons residences, which is rather jarring,
11 disconcerting, quite disquieting and overall a very unpleasant prospect, especially on dark, late,
12 rainy winters nights. Remington will need a better guard, defense and electronic surveillance
13 system in winter 2017, and beyond. Also, very shortly, as alluded to periodically herein, the
14 sheriffs, FBI and district attorneys office will be alerted to the facts that if anything unexpected
15 should happen to Remington, such as coming-up missing on his way home from Westgate,
16 mysteriously dead, killed by unknown means, or in the event that he surprisingly gets run off the
17 road late at night, by some ruthless and fearless driver such as a drag-strip racer, used to the
18 adrenaline of risking his life at 200 mile-per-hour speeds for a few seconds, Etc., THEN see what
19 Skillings whereabouts were at that time. Skillings just happens to be the owner of a super-fast
20 drag-strip racer, and has probably given considerable thought to the specific sharp, dangerous, wet
21 curves between Remingtons two residences. In the event of some unfortunate accident or
22 mortal injury to Remington, the first place to look for evidence would be Skillings house and
23 motor vehicles and a full investigation of his precise whereabouts at the exact time of Remingtons
24 death, and his absolutely irrefutable proofs thereof, should thereafter begin within seconds, before
25 his engine grows cold.
26 Careful discovery will be required to determine the exact communications between Skillings,
27 Olson, Figas and Gans in 2012-2013, as all were clearly and corruptly colluding in the extortion of
28 Figas, which as explained greatly damaged the Burl Tree, in which damages continue and threaten
to destroy Remingtons entire very large and very costly residence. Who knew what, when and
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1 How specific orders were transmitted among these witnesses will a subject of considerable
2 complexity, significance and great interest. There were a complex and lengthy sequence of
3 significant, crucial escalating diatribes, warnings, threats, extortions, coercions, bribes and/or
4 blackmail involving Figas in 2013 and thereafter, which were in effect the opening artillery salvos
5 launched by the RICO enterprise against Remington in this specific case.
6 Figas was very seriously frightened in late 2012, when he hastily remove his excavator in a
7 panic and then six months of subsequent rains occurred. Remington was in frequent contact with
8 Figas in early 2013 and every time Figas and Remington talked things had changed somewhat.
9 Sometimes, Figas was calm and relaxed and solemnly promised to come back in a week or two to
10 finish uncompleted work, but other times he had obviously been recently re-terrorized, and at some
11 point he decided that it was too risky digging anything on Remingtons property and that the cost
12 was potentially too great to bear. And what that exact cost was, and whether it was emotional,
13 financial, fear of some sort of specific physical harm to his person, reputation or his equipment, or
14 was serious fear of something else remains to be determined from depositions, and otherwise
15 discovered, analyzed and authenticated from phone and written records, if any, plus from anecdotal
16 recalls of direct, in- person conversations, among all the relevant witnesses.
17 Obviously, all of the above ties in closely to the Randall crimes enumerated at 3 E. below.
18 What Skillings and Gans do next with regard to Figas, the likely attempted further obstruction,
19 intimidation and extortion of Figas sworn testimony on these topics, whether at his deposition, at
20 trial, or to the district attorney, plus how the enterprise now elects to handle Remington, will now
21 be unpredictable and important relating to how this RICO issue and entire case develops next.
22 2. 18 USC 201. BRIBERY. Several incidents of bribery by the RICO enterprise of varying
23 severity are alleged herein, and probably many others also occurred independently, from the RAO
24 defendants during the late 1990s, and presumably more than 10 years ago, so they are likely
25 exempted by the statute of limitations.
26 Was Figas bribed in 2012-13? Or, was he merely extorted, blackmailed and/or threatened
27 with exposure to the authorities such as the County and the CHP regarding his own crimes,
28 or was he coerced in some other way? The evidence now shows that Hobbs act, 1951 fear
was certainly involved and caused in Figas by Olson and Skillings; however, there seems to be
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1 more to it than that because Figas, even today in 2017 is still very afraid of some sort of
2 unknown RAO retaliation, which Figas is still very reticent to discuss because he is still very
3 afraid of reprisals from the RICO enterprise.
4 3-4. 18 USC 1341. Mail Fraud (overlapping with violations of California B & PC 17, 200,
5 et seq); and 18 USC 1343: Wire Fraud, including frauds consummated over the internet,
6 through email or by phone. Like any criminal engaged in a long-term corrupt cover-up, while
7 simultaneously spending hundreds of thousands of dollars of illegally derived under-the-table and
8 laundered money, on real estate development, equipment, racing vehicles and lavish vacations,
9 Olson has undoubtedly committed Mail and Wire fraud, in every year since at least 1998, as we will
10 prove in discovery. Olson's extensive, very prosperous real estate building projects along Walnut
11 Drive and in other parts of Cutten will be of particular interest, as will all his financial statements,
12 purchases both in State or Interstate, all his incoming revenues both on and off the books, his tax
13 records and an exact blueprint of all his finances, business life and/or other illicit sources of income
14 (such as drug trade, widely reputed in the newspapers among his children and family) since 1998
15 will be examined.
16 Remington does not yet have any discovered documents from among Olson, Kluck, Gans,
17 Mathson, Skillings, other RAO DOE defendants, et al from 2012-16, but assumes that many exist
18 and that all will be of great interest. Written discovery will commence imminently here with
19 depositions to follow at least by the following year, if not sooner.
20 When we soon learn the full scope of Klucks representation of RAO, it is most likely that
21 therell be no attorney-client privilege because of the crime-fraud exception, United States vs. de La
22 Jara, 973 F. 2nd 746 (9th circuit 1992), etc. See you also United States v. Zolin, 905 F. 2d 1344,
23 1345 (9th Cir. 1990), [In order to successfully invoke the crime-fraud exception to the attorney-
24 client privilege, the government must make a prima facie showing that the attorney was retained in
25 order to promote intended or continuing criminal or fraudulent activity.] At the proper time, we
26 will argue the facts, specifically and individually as needed in motions to compel, demurrers and
27 Motion to Strike hearings. How that statute applies to Gans may be a closer question, since he was
28 retained prior to the formation of the RICO enterprise, the latter of which was only formed because
of Gans intrinsic devious and corrupt basic nature and his inability to prosecute his defense on
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1 the merits with no favorable defensive facts, and hence his exact situation and timing thereof is
2 entirely different from that of Kluck.
3 Olson has been covering-up his crimes since 1998 and from his first communications with
4 Kluck, whenever those occurred, so we will assume that all communications are oriented towards
5 future cover-up activity, and his communications with Skillings, by all methods, were frequently
6 about What to do about Remington and Figas, etc. It is also likely that Kluck has been at least
7 loosely associated with Olson and RAO for longer than we presently believe, however what the
8 exact details of that association and representation were or involved would need to be determined
9 during discovery. It is almost a certainty that Olson employed the Matthews law firm to assist with
10 some prior and probably frequent other kind of dispute, during the 1990s and prior to 2014.
11 Therefore, we can now expect Kluck and Gans, being intrinsically unethical, or far worse
12 advocates, will now attempt to argue that they represented RAO, et al on other banal or benign
13 matters which would now be attorney-client privileged, When in actuality their criminal advocacy
14 association began back during the 1990s and flourished during the 2000s when numerous federal
15 and state laws are known to have been violated by defendants. Therefore, Remington will argue that
16 the crime-fraud exception to the attorney-client privilege should be retroactively applied back to
17 approximately 1990. Therefore, Remington will seek all mail and wire fraud evidence going back to
18 1990 as a background to the several related unlawful dumping projects engaged in by RAO
19 throughout the 1990s, and the other illicit and money laundered projects complained of herein.
20 Defendants will battle Remington about release of all of the above incriminating information and
21 documents, but when one or more of the cited criminal investigatory authorities become interested
22 in these cases, defendants will have to get serious about cleanups, just resolutions of these cases and
23 most importantly they will need to quickly and 100% dissolved their RICO enterprise and all traces
24 thereof. Today, Gans RICO enterprise is so blatantly obvious that it is like OJ carrying a 12-inch
25 long bloody butcher knife under his belt in the limousines and through the airports, etc.
26 As discussed below under damages and injuries, Remington and the Burl Tree were injured by
27 Olsons mail and wire frauds despite not necessarily relying on all of them or knowing about them
28 contemporaneously when they occurred, however there was some reliance as indicated. Future
discovery and more detail regarding Remingtons damages coordinated with defendants specific
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1 chronological actions, will further illuminate specific Burl Tree damages. However, simply put,
2 everything Olson and Gans enterprise has done since 2012 has prolong this dispute, increased all
3 Remingtons time expenditures proportionately and likewise reduced the Burl Trees profits
4 accordingly, in direct proportion to Remingtons time spent responding to Gans Enterprises
5 frivolous motions and defenses, according to arguments and proofs below and in opposition to
6 Gans upcoming motion to dismiss this lawsuit.
7 As explained above, Olson and Kluck receive all of Remingtons Motion documents,
8 complaints and letters from Gans (NOT from Remington) by mail and/or wire and communicate
9 about their mutual cover-up strategy similarly and perhaps also primarily in person, at the
10 courthouse as explained above. So far in these cases, Kluck and Olson have done little of substance
11 except to indicate that they plan a full denial and cover-up of all their criminal activity and of
12 course they hope to knock Remington out-of-court on technical legal grounds. For example, their
13 bogus collateral estoppel summary judgment motion in 2014-15 and their various motions to strike
14 and demurrers to Remingtons amended complaints, where Kluck joined with Gans in his
15 opposition motions, but added nothing separately. The main reason that has occurred is that
16 DR140426, The Successive action case where Olson is specifically named as a defendant, and
17 Kluck is planning to represent him, has been mostly stayed for the past two years, including into
18 spring 2017.
19 The cited, critical predicate act by Olson, Skillings (as assisted by Mathson, Gans, et al.) of
20 extorting, intimidating, PLUS coercing and scaring Figas occurred on or about November 28, 2012
21 but then similar acts were repeated at least once during December 2012, and again several more
22 times with different variations, at approximately monthly intervals as alluded to above, into at least
23 May, 2013, and then were partially repeated during 2016. Each act of extortion, blackmail, coercive
24 intimidation and/or bribery was obviously relied-on by Figas, directly causing him to act
25 deleteriously to Remingtons interests and substantially damaging Remington and the Burl Tree in
26 the several ways discussed: Losing major scrap iron sales in Oregon permanently (see #s 15-16 far
27 below); Causing a huge uncorrectable massive slide of more than 1500 yds at the top of
28 Remingtons mountain, which dropped 6 feet down vertically and slumped 10 to 20 feet further

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1 down Westwards towards Ridgewood Drive and the Creek, where someday it will all wind-up, but
2 hopefully not for more than 100 years, however.
3 Kluck, while representing Olson, damaged Remington further in November 2015, by lying to
4 the court about what he purportedly had done to respond to Remingtons default judgment request,
5 and when he had done it, which was statutorily very late.
6 Kluck was several months late, and relied on technical misrepresentations of his actions based
7 on various false statements about what he had done and when he had his default response file-
8 stamped, which he attempted to file only about two weeks after his deadline to do so. Judge
9 Reinholtsen took mercy on him, due to their 40-year relationship, and the prestigious reputation of
10 his law firm and personal stature, and let him answer late without any substance, and merely a
11 bunch of inapplicable affirmative defenses, without any merit. If there had been an objective
12 hearing of the accurate facts and dates, RAO would have been rightfully in default here, and the
13 cases would probably all be over as result, thereof. During that period, considerable time was
14 wasted by Remington and the Burl Tree as Kluck sat in on 4-5 hearings saying very little or
15 nothing. Inferentially, Klucks greatest focus is on his numerous vacations, accompanied by
16 several insignificant, frivolous, inconsequential and nonbinding legal citations threatening that all
17 hell will break loose if anyone attempts to call him, serve him with a document or conduct any
18 casework at all during one of these frequent lengthy trips. That has not been a problem yet, but soon
19 will be, thats for sure. If Skillings or Olson bush-whacks or ambushes Remington and injures or
20 kills them, it may well be during one of Klucks excessive number of vacations, so at that time he
21 may have to cut it short.
22 Additionally, and as described above, June 2016, Kluck spoke to Remington twice in the
23 corridors of the courthouse in order to size Remington up, scare, intimidate and extort Remington as
24 best he could, without having any specific ammunition to employ, hence he accomplished little for
25 his attempted, casual, artificial and unnatural efforts.
26 5. 18 USC 1503. Obstruction of Justice. Like Gans, Kluck and Olson have no honest scruples or
27 ethics with respect to Remington and their criminal contaminated hazardous waste dump, proudly,
28 brazenly and very illegally established here. Olsons direct agent and very long time trusted
employee Skillings was involved here since 2012, and in August 2016 he glaringly lied about
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1 Remingtons involvement and knowledge of the dump in 1998. Remington had easily proven that
2 Skillings was lying with 2003 photos which caused Gans to modify his entire trial strategy by
3 suborning perjury and all his witnesses. However those photos were inexplicably not admitted by
4 Judge Reinholtsen for any purpose and Remington was unable to even show the photos to Skillings
5 although Gans and Mathson knew they were case-changing, legitimate dynamite, and that they
6 undermined Gans entire defense and all Mathsons testimony also. However the jury never saw any
7 of that.
8 As a result of that erroneous evidentiary preclusion and 100+ other related similarly
9 biased decisions, which fatally prejudiced Remingtons case, Judge Reinholtsen may have
10 eventually been disqualified here as the state judge for all purposes, although that has been
11 ambivalent recently and is unknown today, as written during fall 2016. Even in March 2017, all
12 of the state cases are ambiguous and largely mismanaged or otherwise screwed-up mostly
13 because Judge Reinholtsen is far too busy, inefficient and otherwise ineffective overall in managing
14 DR 080678, so what is going to do next there is still largely unknown. However, what is known is
15 that Judge Reinholtsen was not disqualified and strangely wants to continue-on adjudicating his
16 former long-time established law partners case here, where he has shown unacceptable bias during
17 2016, and appears now to be writing a complex ruling which probably will take him many months
18 and then inferentially will be wrong and require an immediate appeal. The inferences of that were
19 strongly present during the February 17, 2017 hearing, wherein Remington presented all of the
20 controlling Supreme Court law that is relevant now, without said Judge ever appearing to be very
21 interested in what said Supreme Court law was with respect to continuing nuisance or trespass,
22 election, or the crucial and salient fact that the jury needs to determine whether Remington has a
23 continuing nuisance and trespass here, and not an ostensibly and inferentially overly biased judge.
24 Although no court has said it are written it to Remington, it appears that DR140426 is now
25 been taken over by a different judge, but there is not yet been a hearing word that could be fully
26 confirmed, and hence that case also remains stayed but not for the right reasons. Very soon,
27 Remington will attempt to unstay that case, because it is entirely independent of these other
28 cases; but, the new judge will have to undoubtably be convinced of that with hundreds of pages of
contested motion documents, unless this Court here excepts jurisdiction and then just takes over all
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1 of this, which would be Remingtons suggestion, request and fundamental purpose for filing this
2 action in the first place.
3 The details of that requested disqualification which took a 19-page sworn declaration to
4 explain, and initially were largely based on the fact that Judge Reinholtsen was a former law partner
5 of Gans and Brisso at the Mitchell firm for about 20 years before becoming a judge. Since Gans and
6 Brisso were Remingtons two arch nemesis in this lawsuit, after four solid months it became
7 apparent that judge Reinholtsens and just could not be neutral and at critical times always favored
8 this former law partners, where you probably hopes to retire very soon, as he already faces serious
9 felony ethical financial irregularities at the courthouse, and probably will not remain on the bench
10 very long.
11 In any case, Skillings was a central Star witness for Gans defense in DR080678 in summer
12 2016, however he can now be totally destroyed in the next trial (Here) with those same
13 inadmissible 2003 photos, which are totally incriminating and conclusive evidence which will
14 easily prove that Skillings committed serial perjury in 2016, and said photos will now be properly
15 admitted initially in this case and not saved for impeachment purposes, which Judge Reinholtsen
16 had denied in 2016. In fact, the aforementioned 2003 photos are so important, entirely conclusive
17 and totally refute Skillings sworn testimony to absurdity that it now seems obvious that Gans
18 cannot use Skillings any further at a trial here, and that puts Gans in a MAJOR quandary because
19 Skillings was by far his most important witness in defense of Remingtons trespassing charges. The
20 trespassing encroachments are here for all to see and Gans only defenses in the past have been the
21 statue of limitations and supposedly consent from Remington, where Skillings lying Word was
22 supposed to prove that Remington consented to the original gigantic contaminated trespass by 60
23 truck loads of contaminated hazardous wastes.
24 That was not true of course but now Skillings credibility has been destroyed, so that puts
25 Gans in quite a quandary it would seem, but like he always does, hell invent, contrive, devise and
26 eventually fabricate some false evidence or witness testimony to keep from conceding and doing
27 the right thing here. One of Remingtons primary trial strategies here is cross-examination by
28 omission. Obviously in eight (8) years of Discovery and preparations for several trials, Gans and
defendants were supposed to divulge all of their witnesses and all of their material testimony six or
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1 eight years ago, so when they fabricated totally new self-serving and false evidence in August 2016,
2 It was obviously phony and obviously fraudulent. However, the 2016 trial judge allowed it all in to
3 the jury, but now Gans must defend it here it, and with proper notice and advance preparation all
4 Gans fabricated evidence can be easily explained and refuted. It must be calmly explained and
5 presented, however which can be hard for a pro per trial lawyer, so in the trial here Remington well
6 have some sort of assistant trial counsel.
7 Remington had the right idea and understood what needed to be done and attempted to do it in
8 August 2016, however, Judge Reinholtsen, again showed his apparent, irreparable bias towards
9 Remington17 and then inexplicably refused to allow simple, basic sworn case documents to go to the
10 jury, like our 2011 special interrogatories which conclusively refuted all of Gans new creative
11 scripted 2016 testimony. In other words, everything Gans witnesses swore to in 2016 should have
12 properly been disclosed in 2011, but it wasnt, because it was not yet needed and had not yet been
13 drafted by Gans as the false, lying fiction mostly for John Mathson, that it was.
14 All of this is somewhat relevant here as background to this RICO action, but ultimately the
15 details of all of the perceived errors by Judge Reinholtsen will be consolidated, condensed down to
16 the top 20-30 and then presented properly in an appellate brief to the first Appellate District,
17 Division five.
18 Olson was subpoenaed for said 2016 trial, but never appeared, so we dont really know what
19 Olsons actual views are on anything, other than to avoid criminal liability for all of his crimes and
20 stay out of prison.
21
22 17
10. Judge Reinholtsen is a very nice man but is no longer the judge here, in DR1140426 and
DR080678 is unclear. Remington had him disqualified for cause and firmly believes that he was
23 biased and prejudiced against Remingtons interests, as explained. The situation, for more than
24 100 consecutive days was complex and enigmatic however and eventually became a chicken or
the egg situation. For example, did Reinholtsens bias or possible bribes of work after his
25 retirement cause him to make 100 or more adverse, one-sided rulings, or were said rulings
reasonable and just happened to come-up Heads 90-100 hundred times in a row, out of justice
26 or the courts honest convictions? Thereafter, said rulings caused Remington to think that he was
27 biased because he acted biased, but actually is it possible that he was not biased? The bottom line
is: Either Judge Reinholtsen was biased or Ruled consistently over more than 100 days as if he
28 were, so the effect was the same and justice was not being served in that court, due to a
combination of error and probable prejudice and bias, or what came out that way in every single
ruling.
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1 6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor by Olson and
2 RAO. As argued previously, Olsons and Gans behavior since 1998 and expressly since 2012-13
3 meet all the criteria of an illegal gambling enterprise. They were not a casino, but plainly they were
4 a gigantic very profitable gambling risk-taking business, and what they did on the Mathsons'
5 property, clearly and obviously met all of the criteria under 1511 of being an actual unconventional
6 form of Northcoast casino in essence. They did not have slot machines, gaming tables, a bar and
7 were not open to the public, however in every other way they were rolling the dice, skipping the
8 proceeds and living off of them tax-free, and acting in all other respects as a criminal gambling
9 operation, which importantly fully met all of the definitions of an illegal gambling business cited at
10 (b) below. The applicable law Under 1511 is:
11 (a) It shall be unlawful for two or more persons to conspire to obstruct the enforcement of
12 the criminal laws of the state with the intent to facilitate an illegal gambling business if:
13 (1) One or more of such persons does any act to affect the object of such a conspiracy;
14 (2) One or more of such persons is an official, employee, or otherwise of such state; and
15 (3) One or more of such persons conducts, finances, manages, supervises, directs, or owns all
16 or part of an illegal gambling business. [Obviously the Olson and RAO conspiracy in the
17 1990s in association with Joe Costa trucking and many other illicit haulers easily meet all of
18 those criteria.]
19 (b) As used in this section, an illegal gambling business means a gambling business which:
20 (i) Is a violation of the law the state or political subdivision in which it is conducted;
21 (ii) Involves five or more persons or conduct, finance, manage, supervise, direct, or own all or part
22 of such business; and
23 (iii) Has been in or remains in substantially continuous operation for a period in excess of 30 days
24 or has a gross revenue of $2000 in any single day.
25 Finally, (2) gambling includes, but is not limited to, (the conventional types of well-known
26 casino games), and obviously here Olson creatively invented a novel and different type of,
27 extremely profitable gambling business, and many other independent truckers also gambled that
28 they could avoid the CHP, Remington and all Californias environmental disposal laws, and save
many thousands of dollars by permanently disposing of hazardous debris on Mathsons and
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1 Remingtons property, and so far that gamble has paid off. All of the other above criteria are easily
2 met as to numbers of people, violations of laws and the length of time and operation, plus the
3 minimum gross revenue of $2000 made in any single day. Remington alleges that RAO easily made
4 as much tax-free pure profit as $20,000 in a day in this illegal gambling operation and probably
5 as much as $50,000, will be DISCOVERED. Olson was very smart in how we conducted this
6 gambling business and clearly was ahead of his time in its scope. Many Northcoast truckers will
7 haul and dump illegally, as the CHP is anathema to the pure freedoms which most truckers aspire to
8 and actually live all day long in these Northcoast forests. But, few if any other trucking and
9 excavation in the history of the North Coast ever conducted such a large scale and financially
10 successful criminal hauling and disposal scheme as this 1998 and beyond project.
11 In the Mathsons' and RAO s gambling enterprise analogy, the latter defendants are the
12 illicit House and Remington is the Mark. Like any gambling establishment, both sides gamble,
13 but the house has a known, insurmountable long-term probability advantage, as Olson, et al have
14 here.
15 Growing out of their gamble from the late 1990s, the present enterprise defendants with their stated
16 objectives and with their overriding goal of covering-up theyre very criminal hazardous waste
17 dump, have unlimited funds to battle one old, under-financed proper amateur.
18 Additionally, defendants have many terrain advantages protecting their ongoing gamble: the
19 dump sites still remain inaccessible to heavy machinery and the very steep terrain and the well-
20 executed, well-hidden original crime scene still works strongly to defendants advantage. Excavating
21 and exposing a 15-foot deep hazardous waste dump on a very steep mountain top slope remains
22 difficult, until Remington either builds a bridge or difficult road into they site for an excavator.
23 Defendants trespassing hazardous wastes are also very heavy, involving gigantic concrete
24 chunks up to 20,000 pounds, and even a large backhoe would be too light, undersized, dangerously
25 unstable, and inadequate with rubber tires, a short, limited reach and insufficient weight or power,
26 to fully explore explore, expose or remove the materials.
27 What is needed here is a large, heavy, long-reach excavator, and it is a pretty large project to
28 get the proper-sized machine into this dumpsite, without it overturning and potentially killing the
operator.
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1 Richard Olson along with the Mathsons' gambled against Remington ever finding-out all this
2 and solving all these problems, and hence their 1998 gambling Business or establishment WON
3 the overall gamble for 18-20 years, as the house would be expected to do, and so far RAO and the
4 Mathsons have already made and saved huge amounts of money, like an ordinary casino. The huge
5 illicit profits made from their gambling establishment here on these dumpsites, has also been used
6 to further invest and to live-on over the past 18 years, which of course is also a violation of 18 USC
7 1956, 1957 and 1961-4, et seq., as below.
8 A substantial portion of the unjust profits from defendants hazardous dump was also known to
9 be reinvested by RAO into interstate Commerce which involved stock and real estate investments.
10 Also, using mostly materials from out-of-state to build more than a dozen so far discovered major
11 residences, their profits made in those derivative money-laundered operations, have been
12 considerable, and have already paid for any possible future ordinary civil (and possibly even treble)
13 damages that might not be covered by RAOs extensive licensed contractors, and Mathsons Gans
14 supervised liability insurances.
15 Here, so far, only Remington has substantial gambling losses today, however he still has the
16 energy and funds to continue with this gambling game at this large outdoor casino which
17 occupies a substantial portion of his property. In essence, as Remington continues his participation
18 in the RAO's/Mathson original 1998+ gamble, where he has the primary objective of closing
19 down defendants very unlawful, presently RICO managed casino, removing it entirely from his
20 site and anticipates getting-paid for his major expenses of doing so. State case DR140426, for
21 damages for the three years prior the 2015, is still ongoing and involves those similar objectives,
22 which is in addition to this lawsuit. However since it is presently stayed, it could stay that way if
23 this case proceeds forward to cover many of those same damages
24 This instant action is for four years of damages from very late 2012 or early 2013 through all
25 of 2016, so the gambling facts or metaphor still applies now as to damages, defendants
26 concealment and the requirement for imminent removal.
27 Defendants crime may have occurred earlier, but like murder it should have no statute of
28 limitations, due to the numerous public interest damages and exceptions of resolving and cleaning-
up these environmental cesspools, which damage Californias drinkable creeks and lower protected
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1 national watercourses, under various public nuisance and trespass state, and their comparable
2 federal doctrines alleged here in Volume I.
3 Also, for years Remington has sued under Californias well-established and permitted
4 Successive Action causes of action for trespassing and nuisance, and will continue to do so until
5 resolution. Remington and the Burl Tree have been specifically damaged here, but so have
6 hundreds of other adjacent up-wind residents (as explained) and also the down-stream fisherman
7 and any ingesters of crabs, clams or ocean fish.
8 So far Olson (along with Mathson, Gans and his enterprise) have rolled-the-dice and WON
9 BIG against Remington and the public and natural environment, and therefore their gambling
10 business remains well-established here and still winning big.
11 7. 18 USC 1512. WITNESS TAMPERING. As above, this statute has been egregiously
12 violated by all Enterprise defendants, however with respect to Olson more discovery is now needed.
13 He Is known to have had other employees and to also have used numerous independent drivers,
14 leased Nichols semi- end dump trailers and/or sub-contractors. As those additional drivers
15 employees, rental businesses and contractors are discovered you can be sure that they will be
16 tampered with by Gans and/or Klucks unethical speeches, plus frequent visits to the unethical
17 horse-shed, which Gans depends upon to fully indoctrinate all his witnesses into the corrupt
18 practices and felony objectives of his enterprise. Said defendants attorneys will also take whatever
19 other supercilious and illegal actions are required in order to alter, influence and corrupt any honest
20 testimony, which almost by definition would then be deleterious to the enterprises objectives. For
21 the past eight years, if something is true, Gans always conceals it, mischaracterizes it, or if all that
22 fails then he writes a script for one of his witnesses to lie about it.
23 8. 18 USC 1513. Retaliation Against a Witness. Both Olson and Skillings are named
24 specifically as defendants here, and also RAO Construction, INC, or whatever their exact tax
25 or fictitious business statement calls themselves. The fact that they claim to be incorporated,
26 although KLUCK constantly intentionally confuses these issue by knowingly falsely referring to
27 Joe Costa trucking as being a defendant, etc. even today is suspicious in itself ,but we will pursue
28 that during discovery. In any event, both of the individuals named above are guilty of retaliation

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1 against ALL Remingtons expert remediation and excavator operator witnesses Bob Figas, Wayne
2 Marsh, and Alves, and presumably some of their employees, to be Discovered.
3 Olson is believed to be the original criminal mastermind here, who predated the enterprise and
4 reportedly, and observably made more than $1 million of illicit profits, whereas his chief skilled
5 employee, and most trusted equipment operator and semi-end dump truck driver Skillings, although
6 he made less money here, is at least as important criminally. So far, all weve seen here is
7 Skillings, and he is a very experienced, but rather obvious liar, with an angry, intimidating and
8 combative disposition, who physically has a tough heavyweight fighters build and an obviously
9 ruthless and hostile nature. His demeanor, as we fully explain previously, during cross-examination
10 and afterwards indicated that he is probably willing to do almost anything, especially if its violent,
11 illegal and will protect Gans, Mathson, Olson or the enterprise.
12 Obviously during discovery we will look carefully into the anything and see from his
13 references and entire education, life, drag racing driving career, sports participation and fighting
14 career, exactly How violent and tough he really is. Risking his life as a serious drag-racer on a
15 crude short Samoa track infers toughness and also implicates his mentality, as well as anything else,
16 and puts Skillings in a slightly different category from the average North coast logging truck driver
17 and machinery operator. Olson is also believed to be involved in the Redwood Acres racing circuit,
18 which also requires a certain reckless mentality, desire to seek thrills and danger, without any fear
19 of death. The significance of that will be discovered and need not be unduly speculated upon here
20 any further.
21 Both Skillings and Olson are believed to have directly confronted, extorted, coerced and
22 intimidated Figas in many ways, for many months, which caused Remington the extensive damages
23 cited above. Exactly what Olson did or said can be precisely determined by a lengthy deposition of
24 Figas, as its been a couple of years since these issues were discussed, and every time we did
25 discuss these things, the details seemed to be a little different. Today there are about 200 new
26 questions to ask here, many relating do the RICO enterprises predicate acts, that were not known to
27 be significant in early 2014-15, and whatever Figas position is today, will need to be corroborated
28 by, contrasted with and presumably disputed during Skillings and Olsons depositions. Those three

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1 important witnesses above had many important encounters during 2012-2015 and many of the exact
2 details, and exact words spoken on specific dates, are presently unknown.
3 Remington last spoke substantively to Figas in December 2015, had some sporadic contact
4 thereafter, about being an expert remediation witness, however he was somewhat reticent to do that
5 at first because some woman lawyer had recently made an ass out of him, and apparently
6 entirely refuted him, over some sort of mathematical, engineering calculations in a recent trial.
7 After Remington assured him that would not be repeated here, for variety of reasons, then Figas
8 again agreed to be an expert witness but inferentially he was extorted again after that by Gans,
9 Olson and Skillings, shortly after Remington made the mistake of disclosing him to Gans and
10 defendants as an expert witness. After that disclosure and apparently during spring 2016, Gans told
11 Skillings, Olson and/or some other RICO member to work on Figas again and make sure he never
12 showed-up here. Today, a year later strongly appears that they were successful. In February-April
13 2016, Figas again began acting skittish, frightened and very unsure and generally upset, as
14 though he might have been blackmailed or severely extorted again by defendants, in any case he
15 acted like he had been extorted and was genuinely frightened into abruptly backing-off from being
16 a witness. Something serious happened in any case. His deposition is now needed to clarify all this
17 because Figas is a very nice and honest person, and is also an important witness for Remington in
18 several areas, but he has been severely tormented by some combination of defendants, and Gans
19 enterprise, and the magnitude and the exact character of the threats against Figas family need to be
20 clarified, and today are not fully known. The plan at the moment is to subpoena him as an important
21 Remington trial witness, because he has repeatedly said he would testify at times, in between his
22 fearful episodes, and also we will take his deposition to attempt to get all details of this harassment,
23 extortion and/or bribery and blackmail onto the stenographic record
24 Ideally, the DA or analogous criminal authorities will interview Figas and the relevant
25 defendants next about this odd and untoward situation, occurring over the last several years.
26 9. 18 USC 1951, Hobbs Act, EXTORTION. Olson, et al, deliberately and believably causing
27 FEAR in Remington, Figas, Bianca, etc.; also, 18 USC 1515 (a) (1,3 & 6) and (b), where all
28 definitions apply above to Olsons hazardous waste dump on Mathsons and Remingtons land, such
as, without limitation: Making false statements, omitting information, intentionally concealing
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1 facts and destroying material evidence. Also applicable here is 18 USC 1952. Barring
2 interstate travel with racketeering or gambling income, BOTH portions of that statute are
3 clearly applicable here, and specifically explained above;
4 10. 18 USC 1956. Money laundering uses are illegal, and Olson, above all others in this RICO
5 enterprise are guilty of same;
6 11. 18 USC 1957 specifically bars property sales and other purchases with laundered dirty
7 money. Olson built several million dollars worth of residential real estate along Walnut Drive and
8 other parts of the Cutten area during the early 1990s, which all involved some degree of laundered
9 money from his unlawful Mathson landfill, according to proofs involving future discovery of the
10 detailed accounting records of RAO's construction, from 1990 to the present;
11 12. 18 USC 1961-4, et seq. Another Money laundering statute barring Olsons illegal, unjust
12 and criminal profits from being invested in other businesses, real estate developments (in Cutten or
13 anywhere), or invested in anything else. As above, since Olson has never yet made a physical
14 appearance in this case and his attorney, Kluck, just barely, I.e VERY rarely ever shows up either, it
15 is somewhat premature today to specifically accuse Olson of additional predicate acts merely based
16 on supposition and inference. We do already know that Olson and Skillings are major Humboldt
17 County criminals based on their activities from 1998, pre-1998 (other illegal dumps, etc) and
18 through the present, and also that Skillings, Olsons primary agent, has already committed
19 numerous federal predicate criminal acts in this case, and elsewhere. However, we will be needing
20 several more years of comprehensive discovery now in order to fully implicate Olson under all of
21 these federal predicate acts. Remington knows a lot about these cases and defendants already, from
22 30 years of related associations and anecdotal circumstantial evidence from the construction,
23 excavation and trucking businesses; but, he also understands that he does not yet have enough
24 solid, irrefutable trial evidence about most things here, and that obviously in a few years his
25 knowledge and solid evidence of all types will be 2-3 times what it is here today.
26 In other words, Remington has enough humility to understand what he does not know and that
27 always is much more, perhaps by 100 times, than what he positively does know about these cases
28 are about anything. We would also expect most likely, and rather certainly, that Olson will be
implicated in many other (including different typed ones) federal criminal predicate acts in this case
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1 alone, which will be alleged by the time of the FAC in this case, if not before. We also know that
2 Olson has been a crook for many years, at least since the 1980s, but that would only be of use as
3 background here, is to his general credibility as a trial witness.
4
5 2E. Kyle Skillings18 is a major defendant here, as discussed above.
6 A-5, Kyle Skillings. Skillings is now quite well-known in these litigations. He is RAOs
7 chief equipment operator who is a big, burly, nasty, mean, ruthless and tough-looking scoundrel
8 who appears to be always looking for a fistfight. Presently he is the only representative of RAO
9 construction and Olson that has been very active here. His state trial testimony indicated that he is
10 going to pretend that he was not affiliated with RAO, but just did Mathson a series of viable favors
11 over three or four months in 1998 by working evenings and weekends to do a $150,000 job.
12 Skillings apparently thinks that Remington and juries are stupid and that we are going to
13 believe that a cold, cutthroated entrepreneur like Olson just provided all of his trucks, loaders,
14 excavators, skilled employees and other equipment to the Mathsons free of charge for many months
15 and then that he absorbed the estimated $150,000 equipment, insurance, maintenance and servicing,
16 personnel and overhead costs, etc himself, as an act of charity for his friends: the Mathsons,
17 whom he barely knew then, if at all. We know all of that are self-serving lies and will be prepared
18 to prove it ALL at the next contamination trial where that will matter. We dont need to prelude the
19 RAO depositions or several days of related trial testimony, however suffice to say here for this
20 court, that happily Remington is a foremost Northcoast expert on trucking and excavation
21 operations and owned and operated his own such small gypo loader, excavation and trucking
22 business for over 30 years, with many of the exact same types of loaders, semi and end-dump
23 tractor and trailers, supporting equipment, skilled personnel, insurance, overhead, California
24 Highway Patrol equipment checks and continuous mechanical problems, which RAO did in that
25 same timeframe. The continuous problems, expenses, personnel, breakdown and safety issues and
26
27
18
This section began on page 6 with enterprise leader Gans, as 2A. On this page we continue
responding to the order to: List each defendant and state the alleged misconduct and basis of
28 liability of each defendant. So far, we have done Gans for 63 pages, Lawrence began on page 69;
John Mathson initially began on page 80; Rich Olson was 2-D beginning on page 97 and Skillings
here is defendant #2E, page 113, or so.
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1 generally the overall lack of prosperity in this region, makes small businesses of that type very
2 difficult, precarious and susceptible to illegal monetary schemes such as implemented here by
3 defendants.
4 Simply put here, rental companies charge $500-1000 a day for that type of heavy and break-
5 down prone equipment or about $100 per hour, for any of it that is operated. Those costs add up to
6 very high amounts, over a period of 3-4 months, and no one provides such services free and in fact
7 a high cash flow is ordinarily required for even a major construction Corporation operate properly.
8 In this case, the evidence indicates that RAO would have had to have cash inflows of a minimum of
9 $100,000 per month and probably 2-3 times that in some or most months.
10 On the other hand, Skillings has already begun substantially and materially lying and
11 misrepresenting about all of that, under oath on the transcribed record and already attempted to
12 argue that RAO had no costs here and everything Mathson received, including about 400 10-yard
13 dump loads of of toxic debris, which the original owners of said debris would have paid OLSON
14 VERY dearly to get rid of, was free and just the act of a friend (Skillings) doing another friend (the
15 Mathsons) a simple and small favor on weekends. RAOs financial records, when discovered, will
16 show that neither Mathson nor Skillings will be able to prove that they paid even one penny for 1
17 gallon of diesel or for any repairs or maintenance for any of that excellent RAO equipment for 3-6
18 months in 1998. If they didnt pay for repairs, insurance overhead, low-boy hauling and
19 maintenance then who did?
20 Fortunately, Remington now knows that Skillings lies fully and almost completely under oath
21 about almost everything, and what that specific string of frivolous lies is going to be, what his voice
22 sounds like and how menacing his posture and demeanor are when hie is intentionally and blatantly
23 lying. That was entirely proven in the August 2016 SOL trial because Remington is a psychological
24 observer in the court room and clearly notice these things. Remington has evidence to prove that
25 and in any next state or federal trial he will easily be able to do so buy using the August 2016
26 transcript in accompaniment with his entirely incriminating and impeaching 2003 photographs.
27 Inexplicably, Judge Reinholtsen did not allow any use of those photos by Remington for
28 impeachment or for anything else of his former law partners star witness, however, Gans and
defendants are beyond extremely worried about those photos, as theyve seen them, verified their
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1 authenticity and they will obviously be admissible at an earlier stage of any future state or federal
2 trial. We all know now that said photos absolutely and conclusively refute Skillings, Olson,
3 Mathson and also their other perjurers, especially using other also unadmitted impeachment
4 evidence. See more details under Judge Reinholtsens section. More details are not needed by the
5 RICO leadership inhabiting the Mitchell firms offices, because Gans knows and recalls all of these
6 details much better than Remington does since he is about 30 years younger, although not 30 years
7 wiser.
8 Skillings is also very tough, unscrupulous, unpredictably volatile and now very angry with
9 Remington, because Remington questioned his false, perjured account of what he claims he saw
10 from his loader in 1998; he also knows that Remington is fully on-to-him and has the perfect
11 rebuttal evidence, motivation and determination to follow-through with it wherever it takes us. In
12 other words, Skillings knows that he is screwed and has his back to the wall now like a wounded,
13 desperate and supremely-powerful and evil Balrog (Lord of the Rings, Book or film number 1), and
14 therefore, Remington now must fear for his own safety, as described above.
15 His specialty is trying to beat-you-up with his eyes, and long intimidating stairs until you
16 decide to look away to avoid bloody battle. Outside of the courtroom, probably his fists or a heavy
17 club would be the preferred weapon of choice. When he left the August 2016 witness stand after his
18 perfectly respectful cross-examination by Remington, his icy, unfeeling and nasty -looking
19 demeanor and attitude, that severely scared the hardened logging boss Figas from participating
20 further in a $100,000+ job in 2012-13, as explained, was apparent. What specific threats would
21 cause an economically poor businessman, behind in his payments, who desperately needs money
22 to pay his crew in the off-season, to RUN-AWAY in a panic from an imminent $20,000 payday,
23 with the prospects of much more imminently? We will find out during discovery.
24 In fact, as Skillings left the witness stand, and walked by no more than 7-feet away from
25 Remington who was then standing at the courtroom podium, Remington clearly read in his eyes,
26 threatening body language and the inaudible movement of his lips, and dismissive body-language
27 gestures slightly towards Remington, as he walked out of the courtroom: Keep this up Remington
28 and Ill kill you, or something similarly violent along those lines, and with analogous substance. It

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1 was unmistakable and issued by an obvious villain, who is not used to be taken lightly, and also
2 appears to be able to and accustomed to backing-up his threats.
3 We will explore that further at his next deposition, but meanwhile his likely future
4 retributionatory actions are of great concern, especially after this document is filed, and he is
5 named as a defendant for his direct and salient involvement here. He may well be desperate,
6 because he has committed serial trial perjury already in the state case, under Gans specific direction
7 and believed protection, but now has no apparent legitimate way out of that now. Skillings
8 knows he lied, Gans knew and most importantly Remington knew and will now attempt to prove it,
9 publicly and on the sworn transcript. We all know that the 2003 photographs are absolute proof of
10 that and that they will also be admissible in all future trials. Hence Skillings is like a cornered,
11 wounded and violent beast, and hence his next actions are unpredictable, but in any event will be
12 desperate and probably violent, because that is his nature. Skillings is a bully that when you want
13 to talk about resolving some kind of a problem, his answer is to beat you up and assert his
14 unlawful will, especially when he has (here) committed hundreds of individual contamination
15 crimes against Remington, has no excuse or apology for it, and now merely wants to avoid going to
16 prison for THEM.
17 Additionally, and problematically, Skillings is no student of the law, but when he eventually
18 figures out over the next 6-12 months that if he continues to follow Gans false script he will very
19 shortly wind-up in a prison cell. Since probably that is not part of his plan, he is expected to work
20 with Gans to see if there is some way you can save face and alter his testimony in the face of
21 absolutely incriminating and feuding 2003 photographs. Remington certainly sees no solution or
22 way out now for Skillings, other than to disappear from these cases and refuse to honor Remington
23 subpoenas. How Skillings will react to all of that than whether he will attempt to take Remington
24 out, as his default solution to many lifes problems, remains to be seen. Here, that wont help him
25 in these cases and will also send him to prison for life or hopefully to death if he decides that
26 Remington is the problem here, when in fact it is really Gans and his enterprises objectives.
27 Whether Skillings is smart enough to figure-all that out is highly doubtful. When you really think
28 about it, like Luca Brassi in the Godfather attempts to do, it would seem to make more sense to
take Gans out than Remington.
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1 Skillings clearly speaks for Olson, Mathson and Gans, but has the big balls needed to
2 perform the mafia enforcers role here such as The Godfathers chief enforcer, Luca Brassi, against
3 Remington, Figas and anyone else that makes any progress towards discovering RAOs buried
4 secrets. Skillings is merely a long time employee and agent of Olsons, and is also Mathsons
5 ostensible agent, implicating all of them with most of what he does.
6 Skillings abortive and frivolous attempt under oath, already, to argue that he is merely some
7 kind of an independent contractor and charitable angel, independent of Olson, and RAOs major
8 six-figure equipment costs, over a period of many months, is actually laughable to another
9 excavation and trucking company owner such as Remington, and will never be supportable under
10 the facts of this case. As explained previously above, Skillings tried to sell the cheap fiction that he
11 was just doing his wonderful, long-time, warm personal friend Mathson a small personal favor,
12 and that obvious fabrication will not play, hunt or hold water, and is simply a lot of obvious
13 BS.
14 Other than Gans, no one concerns Remington more than Skillings, who appears to be possibly
15 emerging as the main protagonist here. John Mathson has individually committed more than 110
16 provable felonies against Remington, which still increase at one-two per week in March 2017,
17 however Skillings now appears to be much more imminently capable of violence and murder than
18 John Mathson at this point.
19 Specifically, Skillings to date has:
20 1. Operated RAOs huge loader, excavator, various Cats (track, blade pushing vehicles
21 from Caterpillar Corporation) and other equipment for many months in 1998. According to
22 defendants sworn declarations in the record, Skillings carefully and intentionally sorted and then
23 placed and burying more than 600 cubic yards (yds.) of, without limitation: asbestos, lead, gas
24 station remediation hydrocarbon-saturated soils, rubber, asphalt and many hazardous and
25 carcinogenic other materials, on and within Remingtons land. Said Remingtons land was very
26 steep, 40-60 degrees, and contiguous to the South, was heavily Redwooded with a major Creek
27 Gorge 30-50 feet below and only 10-20 yards away horizontally to the south. Considerable
28 defendants debris rolled rapidly and inexorably into that creek, just as predictably, and intentionally
as apples falling off a tree onto the ground;
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1 2. Skillings also flatly lied in his Gans written in scripted 2011 declaration, read in the
2 August 2016 trial, and then extensively lied further in court in August 2016, about having
3 nonexistent discussions with Remington about fill, or anything else in 1998. Remington was
4 nowhere near Mathsons property in 1998, and therefore never spoke to any equipment operator of
5 any kind over there, until at least 2004-5. Nor did Remington see or even speak to any Mathsons
6 between 1995 and at least 2003. Remington does not recall any specific conversation with Skillings
7 up by Westgate Drive ever, however if there ever was any brief and insignificant contact with
8 anyone on Mathsons land by Remington, it would have had to be around summer 2005, when
9 Remington came over to that side of this property to landscape it, and was developing that area
10 enough to be able to get-in there at all.
11 In August- October 2005, Remingtons 2016 trial exhibits records prove that he was working
12 right along the Mathson-Remington boundary, within 50-feet of Westgate Drive, planting trees
13 according to detailed plans, and he did fill-in a small shallow area up in that area with his own vast
14 surpluses of dirt, which were seriously in his way, so that he could easily walk into the present site
15 of irrigation tank A.
16 Remington did not need any additional dirt from Mathson, Skillings or anyone else but that
17 whole issue can be taken up again at the next deposition were the 2003 photographs will be featured
18 as well as photographs from 2005, to see if Skillings is able to summon any kind of truth at all from
19 his clear, Gans-scripted memories.
20 3. As documented throughout, Skillings severely scared, extorted and blackmailed Figas
21 in late 2012, into January-February 2013, And then at least until May, 2013 when Figas ordinarily
22 begins his logging. Throughout spring 2013, Figas repeatedly in multiple phone calls considered
23 returning to Remingtons land, he said, but never did.
24 4. Skillings and Olson also intimidated, frightened and extorted Wayne Marsh,
25 Remingtons next projected 2015 excavator operator and possible remediation consultant and
26 expert, giving him the same kind of ruthless, scary and life-fearing treatment they gave Figas
27 continuously after January 2013. All of the specific details of the various conversations, their cause
28 their timeline and exactly what happened and why need to be more fully discovered, however in
November 2015 Wayne Marsh solemnly assured Remington that he would show-up on a Saturday
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1 afternoon right before about 6-inches of rains, after being specifically recommended by Figas. The
2 day before, Remington carefully walked the entire job and discussed it with Marsh in detail for
3 about an hour and everything was harmoniously 100% set-up, but RAO somehow got involved, and
4 the next thing was that Marsh was intimidated into not doing the job.
5 Its been that way for years, RAO is deadly afraid of anyone excavating anywhere near their
6 dump and burial grounds, as explained in detail above, and which fascinating fact will be probed
7 intensively at trials and in depositions.
8 5. In August 2016, Skillings reversed his sworn trial testimony which was fully rebutted by
9 Remingtons 15+ 2003 photographs. After meeting further with Gans to be coached to make his
10 testimony consistent with Gans other previously perjuring witnesses, Skillings completely changed
11 his testimony while under oath on the witness stand. His original declaration had been perjured,
12 however in 2016 Skillings suddenly and imaginatively went from having one meeting with
13 Remington where Remington purportedly requested more fill be pushed over onto his land, to at
14 least TWO such imaginary meetings in 1998. However, Remingtons numerous and detailed
15 photographs taken in 2003 prove that the purported objects which Skillings lied about in his
16 testimony as being there in 1998 were not there, and provably did not occur until after at least 2005.
17 Hence at a minimum, and giving him the benefits of all doubts, what he solemnly swore in
18 great detail, and was positive was there in 1998 because it tied-in with all the rest of his lengthy
19 story, was not there in 1998, 1999, 2000, 2001, 2002, 2003 or 2004. That is because the
20 photographs show that the distinctive objects in question which caught Skillings eye, purportedly
21 and absolutely in 1998, while he was pushing fill around Mathsons land, are just absolutely not
22 there at all until at least summer 2005. Theres no way that Skillings can make that right, he is just
23 flagrantly lying, which is discussed above. Further, we all know it, because it is blatantly obvious
24 given the absolute unquestionable photographic proofs, from all possible relevant angles that we
25 have, which Remington can prove again, just as he proved already. By the time of trial here
26 Remington will have had time to discover additional impeachment evidence in his files.
27 There never was even one such meeting (between Skillings and Remington) in 1998, or
28 any other time, and inferentially therefore there were not TWO either! As discussed above,
Remington never could reasonably even get over to the Mathson line at issue here, across the ravine
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1 and through a horrible field of nettles, and never considered, discussed or planned anything about
2 filling-in the shallow draw at the northern edge of his property until summer 2005, when he put in
3 Tank A, as just discussed above. At that time Remington did need access across the 6-8 foot deep
4 narrow, but treacherous, ravine in that area, where he ultimately used his own approximately 20 yd.
5 of dirt from his own adjacent stockpiles of several hundred yards of surplus dirt which was in his
6 way.
7 6. Skillings intimidation and threats to Remington.
8 Also as just explained above, in August 2016 Skillings lied on the stand as described, and
9 then when he left the witness stand he gave Remington an intense series of very seriously dirty,
10 dagger -like looks, threatening mannerisms and inaudibly mouthed something about killing,
11 harming or doing violence of some sort to Remington, if the latter did not back-off with these
12 photos and unpleasant truth stuff. That incident occurred over approximately 10 seconds as he
13 very slowly dragged himself out of the witness chair and then menacingly kind of slumped-out of
14 the courtroom, only about 7-feet away from the lectern, where Remington was standing and
15 watching him intently.
16 However, Olson is really the key figure here that Skillings merely works
17 for. We need a lot of discovery from Olson, especially, have absolutely zero at the
18 moment, and which discovery should be able to start imminently when the stay
19 in DR140426 is lifted, or in this case. The exact relationship and dynamics
20 between Skillings and Olson is presently unknown, and remains among the most
21 important facts to discover here, and soon. Having worked in the industry and employed
22 many people like both Olson and Skillings, Remington has a very good idea what these two men
23 are like but will prove it during discovery.
24 Skillings has been frequently mentioned while discussing Olson, Gans and Mathson above
25 and throughout these documents. By the time of Remingtons FAC in this case, in 2017-18, we will
26 have much greater actual detail, many new criminal acts by all defendants mentioned here,
27 undoubtedly, and more actual written evidence of criminality, plus crucial financial evidence on
28 Olson, Skillings, and RAO Corporation, if it is still incorporated, plus all other defendants and
enterprise members, which we now lack. Inferentially, Olson and RAO, essentially gave Skillings
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1 his nice new home free of charge, in a very nice Eureka residential subdivision, based on his
2 loyalty, tenure and corrupt service.
3 We also expect to learn that everything that the Enterprise has done over the last several years
4 avoided the tax consequences of the Enterprises almost exclusive use of laundered money, likely
5 since the early 1990s, however that will need to be discovered and similarly proven.
6
7 F. Ryan Plotz, Esq., young attorney and Gans evil apprentice.
8 Gans special assistant, researcher, chief writer, chief confidant, constant companion and
9 apprentice in this RICO enterprise is now almost as guilty as Gans himself. Plotz is very young,
10 perhaps 28, barely 2 years out of law school and a very dutiful Gans protege, stooge and apprentice
11 to Gans in the black arts of unethical legal advocacy, fraud and running a RICO enterprise, in
12 California. Like the Consigliore to the Godfather, Plotz helps-out with all Gans decisions, debates
13 the issues, issues the orders to the enterprise and helps conceal everyones tracks in the cover-up,
14 among a thousand other duties. However much he is paid, appears to be too much, because he
15 rarely opens his mouth and hearings and is walks back and forth with Gans for hours and hours
16 each day without ever doing anything. Inferentially, his time spent at the office is a somewhat better
17 value, however Gans obvious final proofreads and edits are apparent in every document signed by
18 Plotz, so at some point Gans might as well just write the whole thing, but is too lazy and burned out
19 on this case to do so. On the other hand, both Gans and Plotz have buried themselves so deeply here
20 in corrupt deception and falsifications that it must be really difficult to write anything here
21 anymore, and certainly requires a much better memory than Remington has these days, to keep up
22 with all the falsifications and outright lies. Somewhere in the Mitchell firm must be of long
23 document entitled in effect: What we have said about the facts and where we said it, and that may
24 be accompanied by something which says in effect what the true facts are or camouflaged as what
25 Remington has falsely alleged about the issue. In a just world, we could discover that key
26 document that they must have to try to keep their mischaracterizations and perjury straight,
27 however in reality we wont be seeing that document, but we will reconstruct it at their depositions
28 probably. That will be very interesting in itself, because neither of said above RICO attorneys like

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1 to directly lie under oath and declarations or depositions, where their lives can be proven and then
2 they can be held responsible, exactly as we laboriously expect to do here, eventually, over the years.
3 As to the enterprises activities, plans and schemes, Plotzs work is never done.
4 Remington has repeatedly written, sworn and specifically suggested to Plotz for more than two
5 years now that his boss Gans was unethical, had become predominantly criminal; and, therefore
6 Remington has specifically advised Plotz in writing that following Gans orders and his lazy corrupt
7 legal example was potentially a big mistake for his young and mildly promising career, for a
8 San Jose State graduate. In Remingtons humble estimation, which IS based on a pretty large
9 sample size over 10 years, Gans is a preeminent example of an obviously very unethical California
10 attorney, sufficiently to be actionable, under CCP 128.7, which has already occurred and will
11 continue until disbarment. Remington has elsewhere used another 30-50 adjectives and
12 characterizations which need not be repeated here.
13 During the 2016 pretrial hearings and trial, sometimes Plotz was all-in with Gans and other
14 times he appeared contemplative and almost seem to be wondering if a stupid little case like
15 Mathsons', which Gans obviously cannot win by honest advocacy, was really worth potentially
16 and/or sacrificing his law license and entire legal career over. If Plotz now continues on his present
17 course, as explained herein, after a few more years of this criminal activity, he could lose much
18 more than a mere California law license, under the civil or criminal RICO statutes presented here.
19 But, Remington is not here to make threats or extortive statements himself, but merely to attempt to
20 present the facts which he has two this court, and simultaneously informing all of the defendants
21 what the allegations against them are, at this time, i.e SO FAR.
22 However as alluded to above, it is not up to Remington to make idle threats, exhortations and
23 wishful speculations, or to determine exactly what is in Plotzs mind these days, but when the DA
24 becomes involved here in 2017, Plotz would appear to be one of the first for them to approach
25 about making a deal to save himself from ignominy or worse, if nothing else. Plotz is still young
26 enough and his listed predicate acts were mostly writings authored by him but heavily edited and
27 finalized by Gans himself before being issued. Hence, arguably Plotz could blame Gans for most of
28 his substantial number of written mail and wire fraud transgressions with clear extortive and
fraudulent intent. Meanwhile, Plotz remains a huge and inferentially a very weak link within Gans
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1 enterprise and especially to his own personal survival. Related to that, is the obvious observation
2 during 2016, that Plotz has not been fully, wholeheartedly and 100% on-board with everything that
3 Gans has been doing during the recent pretrial hearings, and during the trial itself Plotz did appear
4 to almost separate himself spatially from all of the rampant serial perjuries, and never directly
5 participated in any of it himself. In that regard, Remington could put in a good word for him in a
6 variety of ways if he chose to do so. But, since Gans is so charismatic, Plotz will probably just feel
7 entirely compelled to have to follow the party line with the DA and let the disingenuous chips fall
8 where they may, unless he is a lot smarter than Remington currently thinks, based on many hours of
9 observations.
10 Analogously to a low-level seaman assigned to repair the initial hole in the Titanic 50-feet
11 below the surface, there is now a pretty decent -sized hole, which is rapidly enlarging and Plotz
12 now can either attempt to frantically repair that hole and possibly save the ship and himself, or give
13 up now, escape to a lifeboat and let the ship go-down now as appears to be inevitable and
14 eventually destined to happen, no matter what Plotz does.
15 Since Plotz is so intimately involved in all aspects of the RICO enterprise over the last 2
16 years, virtually everything alleged about Gans could also be applied to Plotz, but with some obvious
17 exceptions of course, as inferred and articulated above. Nevertheless Remington here declines to go
18 down every single predicate act violated by Gans and attribute it also to Plotz, except as to mail and
19 wire fraud, because Plotz does a lot of the emails as Gans assistant. [For example, Remington
20 knows of no examples of direct extortion or Bribery yet for Plotz, but 10-20 cases of flagrant mail
21 fraud should be enough. See below and also extensive section on mail fraud above, under Gans]
22 3. 18 USC 1341. Mail Fraud, which overlaps with violations of California B & PC 17, 200,
23 et seq); and
24 4. 18 USC 1343. Wire Fraud, including internet, email and telephone.
25 Mr. Plotz has authored many documents which lacked proper credible legal authority and in
26 fact when famous authoritative California Supreme Court cases were cited and paraphrased, Plotz
27 very conspicuously, Very knowingly and very offensively regularly omitted material parts of their
28 relevant opinions, or just overtly miscited same. Happily, Remington was familiar with most of the
cases and caught the frauds in real time in several instances, however the court was not familiar the
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1 cases, did not want to become familiar with the cases, and generally as his default position for about
2 100 consecutive days, chose to believe the lying attorney officer of the court, rather than some
3 obnoxious Pro per who maybe just happened to be on top of the law, frequently (but probably not,
4 in the courts view). These cases and issues were debated virtually every day and the court was
5 always patient and inferred that it was going to read Remingtons cases, but if it did, it was virtually
6 never convinced by any of them, all 50-75 California Supreme Court cases directly on point, for the
7 most part. Some of Plotzs miscitations were overtly, and clearly intentionally fraudulent and in
8 other words clearly, and knowingly false interpretations of the case law, the relevant Supreme Court
9 opinions as applied to the law and facts of this case. They had to be. Both Gans and Plotz recall, in
10 their heads without notes or review, the details of the top 40-50 Supreme Court contamination case
11 precedents better than Remington does, yet they persistently forget that back for example teaches
12 that a plaintiff such as Remington does not only get loss of use as a recovery but also remediation is
13 the primary damage sought, and like here it would tend to be many times the value of the lost use.
14 The RICO attorneys know that better than Remington does but also know that their every miss-
15 citation and mischaracterization has a better than even chance of deceiving and falsely influencing
16 Judge Reinholtsen, and those odds are good enough for them to keep doing it repetitively, document
17 after document, in almost always the same manner: Some good, famous cases, including almost all
18 of them ultimately, but mostly bad, intentionally wrong and fraudulent statements of their
19 teachings, intended to confuse, defraud and anger Remington and to deceive the court, which often
20 works, so they keep it up.
21 Remingtons RICO file on Plotz in this category, which has been elucidated elsewhere, so that
22 the defendants know exactly what charges are being made against them, contains 5-6 emails which
23 crossed the line into fraudulent deception. By that, Remington means that Plotz knowingly and
24 clearly intentionally made false representations and knowingly inaccurate expressions of the law
25 and truth, overall to a judicial tribunal, which in this case was Judge Reinholtsen, to an appellate
26 court in a Writ application, and also to Remington, a legitimate legal advocate and adversary,
27 although unfortunately simultaneously also a detested pro per in Californias legal community and
28 court system.

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1 Plotzs intense and unyielding loyalty to Gans and his blind support of all Gans lies,
2 falsifications and perjuries may be touching but fully implicates himself is too many attempted
3 fraud on the court, and have occurred over MANY issues, over several years, and included, without
4 limitation:
Plotzs violated and/or improperly withdrawn hearing stipulations in 2015; Plotzs improper
5
and fraudulent advocacy of the MIL #20 law; Intentionally misinterpreting a federal judges
6
summary judgment orders, dicta, the federal laws of summary judgment principles and how do
7
federal court determines the absence of any disputed facts, without finding the actual facts
8
themselves; and plots also deliberately misinterpreted the meanings of the above, and also blatantly
9 mischaracterized all California State and federal collateral estoppel principles, which was obviously
10 intended to confuse Judge Reinholtsen. In that fraud, Plotz succeeded brilliantly, and inferentially a
11 bit too easily.
12 Plotzs administrative support of Gans in the pre-trial hearings implicates him to the same
13 extent that Gans is guilty. If Gans is fined and imprisoned, why would Plotz be treated differently,
14 just because he is a young kid in effect, trying to please his master or father figure?
Plotz is an accessory to all of these crimes and criminal racketeering activities by attending
15
the meetings, participating in the execution of any and all of Gans criminal wishes, including
16
dealing with all Gans perjuring witnesses and perhaps mostly by aiding and abetting all of Gans
17
obvious criminal activities and assisting in their specific executions, and by not reporting Gans to
18
the appropriate civil criminal authorities.
19
Since 2012, Plotz has represented the enterprise well, by looking the part, even if he is less
20 that a first magnitude of legal scholar, writer and researcher. He works with all the witnesses and
21 presumably helped Gans with their scheduling, coaching and deciding How far they could go
22 with their perjury. For example, Kishpaughs unnecessary repetition of adding a couple of times
23 to his already lie of only one time, related to one of Remingtons non-visits to Mathsons property
24 in 1998, which was undoubtedly all that Gans coached him to say. That is just another example of
25 the issues that Plotz is familiar with and worked on and then tried to help Gans get their perjurers
testimony back in the box, after it was too late, at least for next time.
26
Candidly, when we looked down the 16 major categories of federal predicate acts violated by
27
Gans, Plotz has to date apparently been relatively clean, except in these mail and wire fraud
28
areas, which are his biggest vulnerability. Also, as noted above, Remington has noted some mild

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reticence to fully and wholeheartedly celebrate Gans shocking, outrageous and entirely unexpected
1
massive subordinating of perjury in the 2016 state trial.
2
If Plotz is still here in a year, he will be eagerly deposed about all that he knows about Gans
3
enterprise, to see if hes going to be truthful going forward, or just continue to bury himself in
4
Gans big hole, and then continue to dig himself in really deep, or maybe hell smartly move-on
5
beyond our and the FBIs easy subpoena reach. Of course, if he does resign than his presence will
6 become absolutely beyond critical. Whatever he does, will soon be very interesting. Plotz can
7 either tell the truth in our case, to the FBI, US attorneys or similar criminal authorities while things
8 are still somewhat under his control, or perhaps Gans may try to spread the criminal responsibility
9 around a little further, so he can get off lighter, himself. In any case, Plotz knows everything that
10 Gans knows because he is in Gans innermost circle more so than anyone else, except for possibly
11 Brisso, who also knows and understands the full depth of the RICO enterprises criminality. It
wouldnt be beyond Gans to try to blame Plotz for everything here, but in that case Remington
12
would have to intercede with some fairness, justice and truth, as reflected herein
13
14 G. Paul Brisso, senior and eminent member of the Mitchell firm, Gans
15 main law partner and confidant in this enterprise and a key member of it.
16 Brisso has played a major, CRUCIAL and absolutely key part in assisting Gans in these
17 cases and specifically in this enterprise for many years. Since extensive discovery is needed from
Brisso and an early comprehensive deposition would be a good start, Remington will save most
18
specifics and violations of federal crimes for his future FAC. Throughout these documents,
19
Remington has alleged that Brisso somehow very improperly influenced and/or bribed Melissa
20
Martel as related to Eskos weird appearance and illogical report, unsolicitedly exonerating the
21
Mathsons, based only on Blue Rocks fraudulent data, with no rebuttal; Brisso appears to have also
22 grossly and improperly influenced Judge Reinholtsen, perhaps and inferentially by offering him
23 permanent part-time employment as he wishes, after his imminent retirement or likely or at least
24 justifiable removal from the Superior Court bench, for committing multiple financial frauds against
25 the state, even if readily understandable or even almost justifiable.
26 Nevertheless, for a judge, a felony is a felony and if Remington signed false affidavits in that
27 same manner in exchange for money, he would expect to be in prison by now. Obviously, The
justice system in California is very uneven and dependent upon a persons situation, influence,
28
importance and other intangibles, such as being in Pro per is very anathema to achieving justice,

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but is not entirely preclusive of it, as Remington has won about as many motions and entire cases as
1
he has lost.
2
In any case, significant here in this RICO case, whenever Brisso entered the state court room
3
in the various pretrial hearings, a respectful hush went over the court room, including somewhat
4
imperceptibly over Judge Reinholtsen. Everyone immediately stopped what they were doing,
5
thinking or saying and focused-on the impressive presence of Mr. Paul Brisso. Especially, said
6 court always listened very carefully and intently, and always seemed to find Brisso's comments
7 very compelling, and always accepted his ideas. Remington clearly recalls all that because he was
8 very damned irritated about it, as what Brisso actually says is never wise, smart or especially
9 profound, but his slow and deliberate manner of saying it does command a certain amount of
10 attention, and infers that it must be pretty smart and right, apparently, except with Judge Miles
11 who saw through his BS easily, before we were done with about five consecutive hearings, and then
ruled sharply against him in the attorney fee hearings described herein, and specifically two
12
paragraphs below.
13
Remington doubts that any example could be cited by anyone in these cases where the judge
14
Reinholtsen court ruled against Brisso or decided he was wrong on something significant which
15
he was personally and orally advocating. On the contrary, Judge Reinholtsen appears to be entirely
16
transfixed with Brissos perceived brilliance, which is obviously buttressed by the fact that they
17 happily shared adjacent offices and all confidences no doubt, in Gans and Brissos present law firm
18 for at least 20 years and perhaps 25 years.
19 Brisso proved to Remington and Judge Miles that he was a crook in the 2009 attorney fee
20 hearings, where Brisso somehow self-servingly and corruptly managed to escalate his honest
21 attorneys fees from several thousand dollars to about four times that much, and shockingly and
22 frighteningly into the 15-$20,000 range. Judge Miles fortunately saw through all that, and happily
and justly paid attention to Remingtons comprehensive analysis and reduced those exorbitant
23
corruptly-requested attorney fees down to about $5000, and wouldve easily gone lower but for his
24
reputation and the fact that Remington was somewhat at fault in his basic actions. That was a major
25
victory in 2009 for a struggling pro per to actually incriminate and then almost bring-down the
26
imminent, ethically pretentious Brisso, on a very important issue. Brisso can never be the same in
27 Judge Miles Court and hence Gans and Brisso disqualified said Court in 2015. If Judge Miles had
28 remained the competent, very smart and very honest judge in this case, this case would almost
certainly have settled, been tried, or in any case been fully resolved many years ago. Many years
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ago likely wouldve been prior to 2012 when Gans became so desperate that he had to create this
1
corrupt racketeering enterprise to win using criminal methods, because on the honest encroachment
2
facts defendants must lose.
3
Similarly to Plotz, Brisso is and has been a long-time semi-corrupt figure here, unlike
4
Delaney and Vrieze who have not showed-up yet, or Kloppell whose scattered administrative
5 appearances have been inconsequential, to date, however he has written some corrupt, inaccurate
6 substantive documents. Brisso is older, wiser and probably more confident as a trial attorney than
7 anyone else at the Mitchell firm, however he has proven to be as corrupt as Gans when it comes to
8 falsely inflating his attorney fees in order to extort and injure Remington further.
9 Remington has also received reliable information, from three of his most important expert
10 witnesses, that Brisso has great influence throughout the County Counsels office which probably
includes the district attorney. Remington will be personally and very directly seeking conclusive
11
confirmation or rejection evidence regarding that allegation one way or the other, within 10-days
12
after this document is filed.
13
Brisso's name was everywhere here in 2008-10, when he made false, fraudulent attorney fee
14
requests, double-billed Remington for odd-motion charges and other non-special motion work, etc.
15 Judge Miles and Remington caught him in the act, and his attorney fee requests were reduced about
16 75 to 90% of where he was going with his fees, charging Remington more and more for every fee
17 hearing and every opposition, where he was merely explaining why his work was not fraudulent.
18 Remington should have received attorney fees for his work opposing Brisso, but received nothing
19 except lost Burl Tree profits.
20 Brisso also participated in the federal case which work has been thoroughly discredited in
recent years, where he among other things argued that the state cases were central and that there
21
should be no federal case at all. Then, when that failed and the federal case went his way
22
substantially, he reversed his position 180 and argued the opposite: The federal case predominates
23
and now all Remington state causes should be eliminated under collateral estoppel, a reversal a
24
position which has not and will not prevail. Many other examples exist but Brisso's early 2009
25 errors, and attempted frauds are not involved in this RICO case because they preceded the statute of
26 limitations here.
27 More relevant and timely here is Brisso's inferred bribery or obvious and fully known
28 other improper influence with Melissa Martel, Director of the County of Humboldts Department
of Environmental Health, probably through LAFCo, and related channels according to one
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knowledgeable expert highly knowledgeable and accessible to the higher levels of humbled County
1
government, for many years. Whether through some LAFCo influence, bribery, subtle quid pro
2
quo or something else we will discover, Brisso somehow arranged to get Esko importantly and then
3
dominantly into the case as related to an irrelevant piece of property which is not material to
4
Remington's pollution allegations.
5 Discovery will be needed to determine the exact dates and extent of Brissos involvement
6 with Esko, however it occurred at least in the years 2011-2012 and related improper influence and
7 witness tampering allegations regarding Ms. Hoyos, and all County Health Department employees,
8 have been made herein, which occurred entirely in 2016.
9 Brisso IS a very close and long time confidant of Judge Reinholtsen, as they were closely
10 associated law partners with friendly personal interactions and social relationships for many years,
as explained above.
11
Brisso was a very close confidant of Judge Reinholtsen when they were law partners with
12
adjacent offices, for something over 20 years. During that long formative period, deep, personal
13
friendships were developed, as their families interacted socially, for many years. None of that
14
closeness, reciprocity, loyalty and trust appear to have been forgotten, exceeded or replaced by
15 better friendships, today. Neither has the great respect, which the county counsels office developed
16 for Brisso, when he has headed that office several times, inferentially subsided in any noticeable
17 degree, and clearly has not been lost.
18 In 2012-14, Brisso was believed to have bribed, extorted or otherwise improperly influenced
19 the Humboldt County Health Department, as above and has also made it nearly impossible to get
20 Maje Hoyos to testify in Remington's case. Brisso eventually allowed her deposition by Gans with
no problems, but now that he has seen how damning her testimony is, he has manipulated the
21
county counsel's office to bar her testimony except after Remington jumps through extraordinary
22
hoops.
23
Brisso seems to be the acting city and county council for many cities and entities around the
24
north coast and so therefore today he is also protecting the city of Eureka, as best he possibly can
25 from Remington and his serious asbestos allegations. Boyd Davis who was the Director of
26 Public Works for the city of Eureka in 1998 saved them considerable money by dealing with RAOs
27 criminal hauling and contaminated dumping operation, and now Brisso is one of their main
28 defenders, along with a dozen others named herein. Although Olson in 1998 had already violated
many state and local hauling and dumping laws and regulations in the 1990s, that was long before
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the cover-up and related criminal acts began in this 2012 to the present by this Gans Rico
1
enterprise.
2
Brisso carries a lot of influence with Judge Reinholtsen, as we have repetitively discussed
3
here and whenever he advocated for anything in the courtroom during pretrial proceedings such as
4
collateral estoppel issues, the room went quiet, and almost hushed with the utmost respect among
5 all attorneys and courtroom spectators, when he appeared; and, Judge Reinholtsen appeared to be
6 especially attentive and impressed, much to Remington chagrin as he already wrote above. As
7 alleged, inferentially Judge Reinholtsen has been promised his old office back at the Mitchell firm
8 beginning very soon, and that appears to have biased Judge Reinholtsen in this case, in Remingtons
9 present opinion. No discovery has yet confirmed that, nor is it likely to ever prove that until said
10 judge actually takes a part-time position with the Mitchell firm in a couple of years, as expected. At
that time we will reconsider and reintroduce these allegations in an appropriate manner, as or if
11
required, and meanwhile they are speculative, unproven factually, but very plausible to Remington
12
and his trial team, such as it is, as based on hundreds of facts. Additionally, Judge Reinholtsen
13
swore in his opposition to Remingtons disqualification motion that he was not biased, not bribed
14
by Brisso and not improperly influenced by the promise of a job after his retirement, so for now that
15 declaration needs to be respected.
16 So again, these inferential allegations have not yet been proven in fact, but we are working
17 on it.
18 Brisso is not as overtly demonic as Gans yet in his public activities, but is definitely an
19 influential member of the racketeering syndicate behind-the-scenes and discovery may prove him to
20 be the chairman of the board.
Substantial discovery is now needed, and in progress on Brisso, before he can be absolutely
21
and conclusively tied-into any specific individual federal predicate acts; however, he is believed to
22
have communicated and collaborated with Gans on all of the above felonies. It is clear that he
23
knew about most of them, or obviously should have known, because he is the sharpest, most
24
circumspect and potentially most corruptly devious enterprise member named herein. If Brisso
25 knew about Gans criminal enterprise, acquiesced to it and advised it, vainly claiming inadvertence
26 and naivety now, then Remington will argue in federal court that he is just as guilty as Gans, Plotz
27 or any of the rest of them. However, obviously all Remington do is argue and present the facts and
28 it will be up to another trier of facts to make a determination.

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Brisso was an obvious, very conspicuous and well-known, co-conspirator on many of these
1
issues herein between 2008-11 and had a significant intellectual and writing impact in the federal
2
case, although dividing the labor up, and doing different crimes from Gans, since the latter was the
3
2016 trial attorney here.
4
Brisso was provably involved in some of the RICO enterprises earliest mostly mail, phone
5 and wire fraud around 2012 and somewhat earlier, and some of his 2012- 2016 crimes seem rather
6 obvious, with respect to all enterprise interactions with the County Health department, and he will
7 be heavily targeted when production of documents and related discovery, including depositions
8 commence in this case, but for now we lack a lot of extensive, absolutely incriminating specific
9 proofs of criminal RICO activity during the last four years. He conducted known corrupt activity
10 before that, however most of it predated the RICO enterprise and so he may escape complicity on
those grounds. Therefore, at this time he will be investigated based on his known improper
11
influences and damages caused to Remington from within county government, primarily.
12
Brisso keeps a very low profile in our cases lately and apparently either trusts Gans implicitly
13
or wants to maintain plenty of plausible deniability in case Gans gets caught in his criminal acts, as
14
has now happened.
15 Brisso knows Gans is a big crook, is not as smart as he thinks, and is probably shrewd enough
16 to keep his own law license and himself out of jail, when or if Gans falls. However, like Gans, if he
17 lies extensively during discovery, he risks similarly falling, plus the other severe repercussions of
18 being in a criminal conspiracy, because when one or more of the other numerous enterprise
19 members crumbles, and feels a compulsion to tell the truth, which will inevitably occur, they all
20 can be implicated and fall, as noted. The beauty of RICO, once again is, that if Mathson or
Skillings kills Remington or burns down his mansion under construction, then all who planned,
21
knew about or should have known about it will all be caught in one big guilty net, and that should
22
include Mr. Brisso.
23
In 2008-9, Brisso did 30-40% of the overall work against Remington on these cases, which
24
extended into the 2011-12 federal appellate process. We saw a lot of Brissos writing and the quality
25 of his legal research during the earlier federal"motion to dismiss" in 2009, but then little more. Is
26 probably only accidental, however Brisso went on to bigger and better things at almost exactly
27 the time that Gans took over full control here and that control led very quickly into the previous
28 fraudulent conspiracy morphing quickly and almost immediately into the early stages of this present

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now very mature vast RICO racketeering enterprise and criminal conspiracy, directed against the
1
Remingtons and the Burl Tree.
2
Publicly, Brisso now seems to be about 90% out of the Mathson defense, but privately and
3
secretly Brisso is mostly used for special situations like keeping the Waterboard and the Health
4
Department away from Mathsons land, permanently and keeping Judge Reinholtsen focused on his
5 imminent comfortable retirement and not being indicted for his salary frauds before that.
6 H. As discussed specifically under Gans and Brisso, the overriding law
7
partnership, called: Mitchell, Brisso, Delaney and Vrieze LLP ,attorneys at
8
law is also sued here as a separate entity and RICO defendant.
9
The reasons for that will be made clearer in upcoming motions. Most of the attorneys in the
10
firm have made appearances in these cases against Remington, and there can be no way that all of
11
them are not fully aware of the corrupt acts Gans has done and continues to do, in trying to destroy
12 Remington here, and inferentially he employees the same unethical tactics in all his cases.
13 In any case the entire firm should be culpable for treble damages if Gans is convicted. It
14 seems obvious that the entire firm knows of Gans unethical and criminal tactics and/or should have
15 known in any case. None of them are stupid, so they all know about all of this almost certainly.
16 Additionally, they ALL now know, and could and should put a stop to Gans rampant criminality
17 immediately, which means right now, before criminal authorities take this entire enterprise down,
and also before it becomes public, with the release of these documents. There is considerable
18
interest in the community right now about many aspects of this case and how it has stayed out of
19
the news media this long is hard to explain, and also hard to avoid going forward, especially when
20
our website is completed.
21
Under CCP 128.7 (c) (1): With respect to reasonable ethical sanctions determined by the
22
court under section (b), appropriate sanctions may be levied against the attorneys and law firms that
23 are responsible for said violations. Such violations have been strongly alleged, documented and
24 fully proven by Remington in hundreds of pages since about 2013. Further, (1) if warranted, the
25 court may award to the party prevailing on the motion the reasonable expenses and attorneys fees
26 incurred in presenting or opposing the motion. Absent exceptional circumstances, a law firm shall
27 be held jointly responsible for violations committed by its partners, associates, and
28 employees. Ethics was a big issue to Remington for many years, and now is still included as
background, however the criminality, fines and imprisonment which result from a RICO conviction

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here, now vastly supersede mirror ethics problems, violations and little transgressions, and so are
1
left in here as a vestige of past complaints but are certainly not emphasized any further. RICO
2
convictions against the named attorneys should also result in appropriate ethical sanctions under the
3
above -cited 128.7 statutes.
4
What are the exact hierarchy, chain of command, structure and physical organization of
5
this RICO enterprise? Those issues will be discussed below, but also see volume III for
6 relevant figures, photographs and various graphical organizational hierarchies and charts.
7 Although somewhat nebulous and informal, it is clear that the central offices of the RICO
8 enterprise are located within the Mitchell firms building at 814 7th St., Eureka, CA. That fact is
9 important.
10 That location is not in doubt, as all predicate acts, decisions, wielding of power and all
11 responsibility ultimately centers at that location. 814 7th St. is analogous to the Godfathers
12 residence, from which he conducts most, but obviously not all, of his criminal mafia enterprise
13 business, which specific criminal orders emanate from one or more centralized offices and
14 conference rooms.
15 Gans gives most of his orders from there by phone, internet or letter, and also conducts most of
his witness interviews there, and hence issues the majority of his oral orders from those offices.
16
Obviously, that does not mean that he cant make phone calls and issue orders from his own home,
17
car or by cell phone from anywhere, such as the corners of the courthouse as he has been seen
18
doing repeatedly.
19
The other utmost key authority and responsibility figure here is Linda Lawrence, who is
20
believed to still reside in Sacramento California. It is also believed that her primary means of
21 communication with Gans is by telephone and letter but probably speaks to them in person several
22 times per year.
23 RICO enterprises are complex and very, very secretive and therefore no organizational chart
24 or formal records exists of any of the RICO enterprises elicit communications and actions, at least
25 which are acknowledged by or drafted by themselves. On the other hand, what Remington has
26 produced himself from a solid 10 years or more of experience with this RICO enterprise and its
27 precursors is known to be extremely accurate, and essentially impregnable from serious attack.
28 As explained elsewhere, the Mitchell firm is the command center of the RICO enterprise,
provides its home office, and virtually all of its office equipment, secretarial staff, computers and

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finances all aspects of the RICO enterprise, almost entirely from funds received from Linda
1
Lawrence of Allied insurance, and then to a much lesser degree, from their own profits and
2
overhead charges as needed.
3
Importantly, the Mitchell firm, although the headquarters for this alleged RICO enterprise, is
4
not exclusively a criminal enterprise, most likely is not even primarily a criminal enterprise,
5
although potentially they may be involved in numerous other independent RICO enterprises, they
6 still obviously DO do considerable other legal work, independently of anything related to
7 Remington. The Mitchell firm advertises and presents themselves as a fine, eminent and
8 extraordinarily ethical Northern California advocacy firm, and although that claim is provably
9 here to be beyond patently ridiculous, and will be flagrantly refuted going forward, it is true that
10 they are believed to still now do, and to have done some legitimate legal work over recent years,
11 and in all probability the attorneys not named and associated with Gans in this RICO racket, are
probably legitimate attorneys that may have no specific or direct knowledge of Gans long-time
12
corrupt legal practices, as complained of herein.
13
Although, as strongly noted above, they obviously should have known, and should
14
also take it upon themselves NOW, to read this RICO complaint, understand it and investigate
15
Gans activities and Remingtons allegations thereon, independently. Very obviously, if the entire
16 firm does not start taking serious strong and immediate action against Gans enterprise starting
17 today then they will rapidly become highly negligent themselves and quickly also become deeply
18 implicated themselves, as soon as they begin assisting Gans and Brisso, et al, with their massive
19 continued cover-up, which also will begin and/or continue with great seriousness and earnest on the
20 day that these documents are received. All subsequent document-shredding after these documents
21 are received will be duly noted by someone around there and these RICO members do not need a
pro per to explain what obstruction of justice is, means and what its ramifications could be in a
22
federal case.
23
At the very least, the other unnamed and unknown Mitchell attorneys are on the edge of a
24
giant cesspool surrounded by several active hornets nests, and have now been put on notice that
25
they are, at a minimum, somewhat associated with Gans criminal RICO enterprise, and exactly
26 what those associations are and/or whether any joint or otherwise extended partnership criminal
27 culpability is inferentially, conclusively or absolutely beyond any doubt attached to those
28 associations, will be for others to decide.

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In other words the several cases being prosecuted and defended against Remington are far
1
from the only activities which the Mitchell firm engage in. However, as of 2016-17, all work done
2
in the Remington related cases is now allegedly done by said Gans RICO racketeering enterprise,
3
which operates directly and exclusively out of the Mitchell firm office building.
4
Additionally, where does the RICO enterprise meet? Or, do they ever meet for any reason
5 or all get together, or would there be any reason to do that? Discovery will perhaps provide
6 further information, as needed, however preliminarily there would not appear to be any reason for
7 more than a few members of the enterprise to ever get together and meet as a group. The closest
8 that they have come to that to date would appear to be in their August 2016 SOL trial coaching by
9 Gans where one or possibly two at a time would come in to Gans conference room and meet with
10 them, and then later, two or three would be sitting out in the courtroom corridors (e.g. in August,
2016) at the same time, but likely not communicating with each other, or in many cases NOT
11
knowing each other. Enterprise members do NOT need to know each other at all, because all
12
intelligent decisions are made by and through their CENTRAL COMMAND: Gans, Plotz, Gilbride,
13
Lawrence, and Brisso at times; and therefore, in most known cases the only common person that
14
any of the witnesses would know would definitely be Russell Gans, and in some cases also might
15 be John Mathson.
16 Generally, at any given time especially during a trial it is almost a certainty that only Gans,
17 Plotz and John Mathson would have any idea who the enterprise members are, what their functions
18 were supposed to be, or even know what they looked like. Obviously in this sort of trial-oriented
19 and crush Remington at all costs, no matter what it takes RICO organization, there is no need for
20 most of the members to know anything about what the others were doing, and in fact it is a near
certainty that Gans keeps everything he is planning, scheming and/or doing very secret, especially
21
the total corrupt and criminal nature of his objectives and intentions against Remington. In fact, it
22
has been observed and written by defendants that what Gans actually does tell his enterprise
23
members is rarely the truth, nor does he ordinarily seek to evoke the truth from them, but rather
24
some variation on the facts as written in his trial scripts, plus a very few truthful elements mixed-in
25 to make it all somewhat plausible and believable.
26 Therefore, the Mitchell firm is a separate partnership entity, analogous in structure and
27 organization to a small corporation. It has some kind of an unknown hierarchy for making
28 decisions, presumably with Brisso normally getting the last word on most important things after
considering the input and positions from the other major law partners. Obviously a law partnership,
185
including the Mitchell firm, makes many decisions on many matters that are totally independent
1
from, and 100% unrelated to this alleged RICO enterprise directed against Remington, his property
2
and the Burl Tree business. But, as explained: The RICO enterprise herein alleged is NOT the
3
Mitchell firm, FAR-FROM it, as it spreads MUCH wider than that. Conversely, the Mitchell firm is
4
NOT a RICO enterprise per se (yet) as it is still believed to do a variety of other good and probably
5 legitimate lawful OTHER work, which especially applies to the several as yet un-named and
6 unknown other Mitchell attorneys.
7 Remington has worked in many large corporations with clear and definite organization charts
8 and command structures. It would take another 4-5 pages to explain the well-known and obvious
9 organizational structure that this week organization has which operates out of the Mitchell firms
10 offices. The loose association of small businesses and many unaffiliated individuals only has an
ascertainable structure to Gans and Remington but it is clearly apart from its criminal activity
11
against Remington. In other words, the RICO enterprise has committed and continues to commit
12
numerous alleged RICO predicate acts, but those acts do not necessarily or necessarily always
13
delineate the enterprise. This is a complex philosophical area over which courts disagree, and
14
arguably the RICO enterprise only shows itself visibly when committing predicate acts against
15 Remington. On the other hand, the enterprise itself, or parts of it acting under Gans and Lawrences
16 control, potentially could do legal acts, occasionally, or even do some work not directly related to
17 the RICO enterprises objectives, and then get paid for it by Gans who is reimbursed by Lawrence.
18 Many hypotheticals and possibilities exist, however the basic structure and organizational
19 Hierarchy, planning and command structure has probably been expressed clear enough for this
20 stage of the proceedings. Like a battlefield general, Gans controls almost everything tactically,
planning-wise, strategically and logistically, etc., but does have other decision-makers above him,
21
analogous to the Pentagon, Congress or the American people, in terms of a US battlefield
22
commander.
23
Put another way, Gans RICO enterprise is simply of form of organized crime but potentially
24
even in organized crime organization can occasionally, or potentially frequently, do acts which are
25 not specifically crimes such as making a donation to a charity, every day or five times every day, to
26 cover up their illicit activity. Further, as explained all the individual components of the enterprise
27 are ordinary, believed to be mostly legitimate small businesses and various innocent-looking
28 unaffiliated individuals (some of whom are clearly, highly questionable psychopathic criminals),

186
that mostly presumably conduct ordinary (mostly) honest lives when theyre not associated with
1
Gans and doing his evil enterprises biddings and corrupt tasks.
2
Finally, If one accepts the given that Gans is unethical and corrupt in these Remington
3
cases, and inferentially in all similar types of cases which he probably handles, another interesting
4
RICO structure hypothetical exists, as follows.
5 Assuming that Gans now has other similar contamination or real estate related cases, Or will
6 have during the course of this federal lawsuit, it is highly likely that Gans will take a significant
7 portion of his enterprises soldiers in this case and use them in other cases. Right now, the enterprise
8 could be broken up in several ways: There are the Mathson, RAO and Remington cases directly-
9 associated witnesses, and then there are a variety of others that could be used in any case, the latter
10 would include all of the lawyers, the courthouse saboteurs, the judges, if any, and all of the
environmental engineers and some of the others mentioned herein. At present, possibly the variety
11
of others is only about 40% of the approximately 35-40 enterprise defendants, near defendants and
12
others directly associated with the enterprises work against Remington, but thats a significant
13
number. Therefore, there is a real possibility and a strong likelihood that Gans will at some point
14
use part of this RICO enterprise to do other organized crime work on his behalf. Again, as an
15 analogy, that would be like Gans attempting to assassinate the leader or members of a competing
16 Mafia crime family using some of the same soldiers that he used against Remington, but not all of
17 them. At this point, well see what develops in the future, because Gans present RICO enterprise,
18 employed exclusively against Remington, has a very clear and identifiable structure and purpose
19 as far as Remington is concerned, or in other words as it relates to him. But, if it is not so clear to
20 the court, we can certainly provide additional detail in future written documents or preferably oral
forums, where specific questions can and should be asked, rather than these long explanatory,
21
somewhat repetitive monologues concerning what may or may not be of specific interest to this
22
court.
23
24 I. Jeff Nelson, CEO of SHN Engineering and Consulting Services.
25 1. John Aveggio worked for Nelson and SHN as their principal scientist for about 25 years,
26 and was Remingtons imminent and sole environmental engineer, scientist and expert in these
27 cases for about two years and until his untimely death January 2012. Aveggio was clearly the best
28 environmental expert in Northern California, was totally honest, dedicated and had the perfect
authoritative and common-man like demeanor for a smart scientific expert, and he was entirely

187
unbeatable in our 2011 litigation. Gans and Linda Lawrence knew that and tried very hard to end
1
these cases by settlement in August 2011 at the Judge Reinholtsens settlement conference and
2
nearly did so. Had Aveggio lived, defendants could never have tried this case and it would have
3
ended many years ago.
4
Aveggio had full insight into Gans bogus and fraudulent defenses and it was he that fully
5 exposed the totally incompetent nature of Blue Rocks 2010 test results, among many other major
6 revelations of that type. Aveggio was exposed to many toxic materials in his career, but not the least
7 of which were below Mathsons dump on Remingtons land, which also have made Remington
8 almost deathly ill for several years, which continues. In other words, there are lethal pathogens
9 deriving from Mathsons contamination.
10 Aveggio was entirely invaluable to Remingtons case in every way, as he did or advised on all
the environmental studies, litigation and theoretical planning as to how to approach these cases, and
11
since he was inarguably a super-expert in this county, he has been impossible to adequately or fully
12
replace. His death has still not been fully overcome and Gans has taken advantage of it ever since
13
then. With Aveggio in the case, Gans had no viable defense and HAD to settle it then, and did
14
attempt to seriously do so in August 2011, but after Aveggios death the enterprises objective
15 became total victory only, a total annihilation and crushing of Remington, whereas settlement is no
16 longer an option. This court should understand however that Remingtons environmental
17 claims here are very valid and Have always been fully understood by the defendants to be
18 such. Why else would they attempt to end these cases with a payment of $100,000, and drop their
19 own frivolous countersuit DR 080669, if they did not believe that they were likely to lose much
20 more than that if these cases what the trial? After the death of Aveggio and their pipe dream of a
collateral estoppel-based dismissal of all allegations in all courts, defendants gained a false sense of
21
security that they could inflict a total defeat upon Remington and abandon all principles of right and
22
wrong or remediation for Remingtons or the publics good.
23
2. Gans improperly influenced Nelson. As discussed much more fully below under the
24
Nelson timeline it is clear that during the exact period between April 2013 and August 2014,
25 Gans racketeering Enterprise gained access to Jeff Nelson as explained below, and corruptly
26 influenced him, irreparably prejudicing and damaging Remingtons case. Jeff Nelson then emerged
27 as a prominent and devastatingly damaging RICO enterprise member, fully under Gans corrupt
28 influences, intimidation, extortion and suspected probable bribery, as relating to FOGET, and as
described in detail, below.
188
3. FOGET. Five (5) months after Aveggios untimely death, Remington contacted SHN
1
about replacing Aveggio with their next best scientist, who had taken over Aveggios job. He was
2
also a very experienced engineer with more than 20 years a relevant experience, whose name was
3
Mike Foget.
4
Mr. Foget was VERY excited about getting into and learning to do litigation support, like
5 his friend John Aveggio, and promptly visited Remingtons land on July 12, 2012 for 2 hours.
6 Thereafter, he studied Aveggios file, Learned and/or knew about all his test plans and conclusions
7 and was fully prepared to take over the job as Remington sole engineering testing expert, and
8 Remingtons only actual trial expert to present testimony before a jury. Foget also was emotionally
9 invested in this case to continue his friends good work and in effect avenge his death, and gain
10 his approval as he watched this case unfold from on high.
Jeff Nelson had complete knowledge of the situation and had fully approved Fogets
11
position as Aveggios replacement and Remington had paid SHN another $600 in August 2012 for
12
Fogets introductory work, and Remington himself put in MANY more thousands of dollars of his
13
own time to try and ease the transition for Foget, and to fully prepare him for a career in litigation
14
support and to present Remingtons entire case eloquently and correctly to a jury.
15 During Fogets July 2012 visit to the Burl Tree property, he reasserted the validity of our
16 litigation services contract, said that he had obviously discussed all this with Nelson and they had
17 fully agreed that he would take over ALL of Remingtons litigation support duties and get
18 Remington through all trials, exactly as Aveggio had planned to do, and absolutely would have
19 done had he not died untimely.
20 Foget and SHN sent Remington a substantial bill thereafter, which was promptly paid,
consummating the new, firm an inviolable oral contract codicil to the original January 17, 2011
21
written contract.
22
In addition to the $10-$15,000 that Remington had already paid Aveggio in this case on the
23
original contract, Remington paid Foget that additional $600 for his introductory work. Also
24
crucially important here is the $25,000+ of Remingtons own time that was involved in working
25 with Aveggio and Foget, training them both and generally communicating with them both about
26 what deposition and declaration topics were needed from us, and would be sought by Gans and we
27 also thoroughly reviewed Gans multiple experts declarations, with both of SHNs men.
28

189
1 Thereafter, the state case was stayed for approximately 2 years while a 9th circuit appeal was
underway. During that time Remington updated Foget about the case status and general situation
2
four (4) different times at several month intervals, between December 2012 and June 2014.
3
4 4. SHNs trial litigation services contract unilaterally terminated by Nelson.
5 On August 25, 2014, Remington was ready to resume trial preparations for an imminent
crucial life or death important jury trial, which could have been abruptly scheduled as early as
6
September-October 2014 and he called Mr. Foget to inform him of that fact and to meet further.
7
Remington was then very shocked to learn that Nelson had pulled-the-plug 100% on Foget,
8
removed him entirely from Remingtons case, and unilaterally decided that he could not be
9
Remingtons expert NOW after all, or EVER. Nelson deceitfully claimed that SHN was going to
10 unilaterally and without discussion, or alternative presented, just (purportedly) abruptly stop
11 doing any litigation support entirely, because Nelson unconvincingly claimed that he just
12 doesnt like litigation support. That arrogant, self-serving and prima donna-like statement, which
13 is not likely to be Nelsons true policy or motive, didnt make sense then or now, and infers even
14 further the strong pressure which Gans applied to him through corrupt means. Why SHN would
15 abruptly violate an obvious and bona fide contract and then walk-away from a very easy $20,000 or
more for some less then fully deployed employee, who merely had to sit on his butt, and answer a
16
few rather easy questions which had already been thought through and answered by Aveggio years
17
before, has not yet been adequately answered.
18
Remington spoke to Nelson at length on the phone on August, 25, 2014 and once thereafter,
19
trying, with absolutely zero effect, to convince him to reinstate Foget into Remingtons case.
20 Nelsons mind had obviously been 100% made-up to breach our contract, long before Remington
21 spoke to him on the phone. It is not important to paraphrase that hour-long conversation here,
22 however Nelsons basic position involved suggesting that Remington use Aveggios deposition for
23 the jury, and nothing else. At one time in 2016 Remington did even contemplate doing some of
24 those pitiful half-measures, such as reading Aveggios deposition to a jury if permitted, but also
25 with another major environmental expert, Dr. McEdwards who also required at least $20,000 to get
up to the speed of Aveggio and Foget, here. However, again Gans and his enterprise foiled
26
Remingtons plan and Nelsons suggestion and have so far successfully objected to using Aveggios
27
deposition at all, and so far have blocked it. Because of Gans enterprises influence over Nelson,
28
Remington cannot now even use Foget to read his BEST friend John Aveggios two lengthy

190
depositions, declarations, numerous field notes, last written file note about declaring an imminent
1
danger and threat to health, all nearby life and the environment, and also his final deathbed
2
comments made slightly before his death, to a jury.
3
These decisions by Jeff Nelson have greatly prejudiced Remington and we now have learned
4
that ultimately they were brought-about through Gans extortive racketeering enterprise exerting
5 pressure on Nelson, through Foget plus through several additional low-level testing technicians,
6 including the countys tester who briefly visited and tested on Remington site in December 2011.
7 All details of these interactions need not be presented here however Maje Hoyos, a Remington
8 Health Department tester and witness, was the one who alerted Remington to these unexpected
9 dynamics, odd illogical changes and influential interactions here. Also involved in Gans
10 racketeering enterprises extortion and/or improper and corrupt influencing of Nelson (the exact
details of which are to be discovered), was Ferrimans Blue Rock tester, who was also a friend of
11
said Countys tester, SHNs tester and even LACO Engineers tester, all who were purportedly
12
involved in this witness tampering, obstruction of justice, and bribery and/or extortion of Foget, and
13
acted like a testers labor union of sorts.
14
The bottom line here was a nasty Gans-inspired conspiracy which was very detrimental to
15
Remingtons interests, wherein what we now have is: The Gans and Ferriman Enterprises faction
16 and conspiracy, long after Aveggios death, abruptly began surprisingly accusing Aveggio and
17 Remington of some kind of phony testing or evidence tampering or similar false allegations, which
18 still need to be determined exactly, and are addressed further below. That was a pretty dirty method
19 of attacking the North Coasts preeminent tester and expert, after he is dead, buried and there is
20 nobody left at SHN to defend him and his legacy, now that his two major professional supporters,
21 Nelson and Foget, have inexplicably abandoned him.
22 On or about August 27, 2014 Remington sent Nelson an 18-page letter explaining the
situation, Aveggios crucial role, the extreme prejudice and bias that this expert removal was
23
causing Remingtons case and urging Nelson to reconsider and to specifically allow Foget to
24
continue here as contracted. Simply put, Nelson refused, and two months later he had an Arcata
25
lawyer from Stokes, et al, contact Remington with that refusal, as explain further below.
26
On August 26, 2014, Nelson sent Remington a cursory letter unilaterally terminating our
27
agreement under 5.S (ii) of the written contract. Remington rejects that termination believes their
28 grounds for doing so are self-serving and entirely illegitimate, and accordingly Remington will be

191
prosecuting that contract violation separately from this RICO matter, in the event that treble
1
damages fail here.
2
What SHN has now done is to renege on a clear, unequivocal and firmly reaffirmed by two
3
years of unmistakable, absolutely unambiguous and clear course of conduct, founded on a written
4
contract.
5
Essentially, after doing the preliminary work the easy lucrative and profitable tests, and then
6
banking all of Remingtons money, SHN refused to do the final report so in essence all the
7 money that Remington invested has been lost in Nelsons swindle or fraudulent scheme, in
8 conspiratorial collusion with Gans RICO enterprise. Remington seeks a full and 100% refund,
9 plus the many other cited damages, most especially for his own time, indicated, now as treble RICO
10 damages. If those damages are not recoverable here than they will eventually be recovered in a
11 separate, unrelated contract breach lawsuit as needed. In any case, this action now tolls the statute
12 of limitations for contract and puts SHN and Nelson fully on notice of the detailed charges against
them.
13
However, this section now is devoted to the peculiar circumstances, timing and exact words
14
used by Nelson, Gans, Hoyos and others which inextricably link Fogets removal from this case to
15
this RICO racket, which RICO enterprise is intended to stop and destroy Remington by any
16
extraordinary or extra legal means possible. Removing Foget and then slandering Remington
17 around the Eureka environmental consulting community, including LACO Engineering, prevented
18 him from securing any other top class local expert, so Remington was forced to go to Laytonville
19 and locate Dr. McEdwards in order to keep this case going. Dr. McEdwards is very good, but no
20 one can replace the expertise, impressive personal qualities and perfect demeanor of Aveggio. That
21 necessary replacement greatly increased Remingtons costs, which he could ill-afford, severely
22 prejudiced him and treble damages will now be sought for all the problems that have ensued.
23 On October 5, 2015 Remington sent a Formal Demand Letter to Nelson for approximately
$39,000 total damages, which was flatly refused with a perfunctory one-page letter from Stokes and
24
Hamer, et al, an Arcata California law firm, which essentially attempted to deceptively, in-artfully,
25
illegally and wrongfully argue that Aveggio was actually NOT hired as a trial testimony expert only,
26
but for some other unknown purposes. In any case, Stokes and Nelsons defense makes no sense
27
because obviously Remington was not going to spend $40,000 on Aveggios training, detailed
28 document preparations, Declarations, two lengthy depositions, multiple visits to perform multiple
tests, and to learn a thousand other site details involving the dumps volume, illegalities, exact
192
contents, lateral extent etc.; ONLY to then train some OTHER, new and unavailable second
1
person to learn all that again, at the cost of another $40,000, to present Remingtons case to a
2
jury under oath! Does that make any sense, Nelson, et al?
3
SHN has now elected to litigate this matter in San Francisco federal court, under the specter
4
of treble RICO damages rather than to refund all of Remingtons paid-in money, or compensating
5
him for his own time wasted, plus the other damages alleged, some of which are now potentially
6 treble damages, as may be recovered herein in a proper case. After the Gans enterprise and/or
7 testing technicians links are established in depositions, total damages in the six-figure range will
8 eventually be requested and probably recoverable against this defendant.
9 5. Aveggio was hired to test as needed and then to testify at all trials in this dispute and to
10 represent Remington as his sole environmental expert in all related trials, and to do nothing
11 else.
Logic, Truth and common sense dictate that Aveggio was always Remingtons only expert all
12
along, and he was hired to do ALL those things, BUT MOSTLY AND SPECIFICALLY TO
13
testify about everything known in the case in front of a jury, and obviously no one else was ever
14
supposed to do that until Foget and Nelson solemnly contracted for Foget to do the exact same
15
things at trial that Aveggio and Nelson had agreed for SHN to do in 2009-11, and Aveggio and
16
other SHN employees had been extensively trained for two years to do.
17 6. Nelsons cited actions, have violated many state and federal laws. Additionally, what
18 Nelson did has always been logically absurd and obviously morally wrong, but to yield to Gans
19 pressure, intimidation and/or threats, and the other influences detailed below, specifically violated
20 several RICO predicate acts, which means criminal laws were violated that have penalties of finds
21 and/or imprisonment, or both. Simply put, Nelson violated the following laws, inserted himself into
Gans enterprise, including, without limitation and at a minimum, as based on our best information
22
before discovery has begun in this case:
23
24 1. 18 USC 1951, Hobbs Act. EXTORTION, deliberately and believably causing FEAR in
25 Remington, plus directly caused or contributed to virtually all of the numerous types of
psychological, emotional, LEL, special, punitive damages and all of the related costs itemized in
26
the Harm and Relief Requested sections ;
27
2. 18 USC 201. BRIBERY, several inferential occurrences of that are alleged, related to Nelson
28
and perpetuated by Gans, Plotz, Ferriman, Brisso and/or other enterprise members;

193
3. 18 USC 1341. Mail Fraud, overlaps with violations of California B & PC 17, 200, et seq
1
with respect to all mailings between Remington and SHN since 2010, wherein Aveggio is a
2
representative of SHN Corporation, falsely represented that he would support Remington to,
3
through and beyond trial and not just give the money to Nelson and run. Nelson and Gans
4
have now gravely dishonored Aveggio and will eventually ruin their reputation in the process;
5
4. 18 USC 1343. Wire Fraud, including internet, email and phone, between Nelson and
6
Gans Enterprise members and between Remington and all members of SHN for at least six
7 (6) years;
8 5. 18 USC 1503. Obstruction of Justice. Gans and Nelson, in combination obviously have no
9 honest scruples, good faith or proper business ethics;
10 6. 18 USC 1511. Obstruction of law enforcement; here, Nelson is now a gambling
11 establishment as he rolls the dice against treble damages;
12 7. 18 USC 1512. WITNESS TAMPERING. Under the enterprises influence, Nelsons tampering
13 with Remingtons fairly contracted for litigation support witness, Foget, was prejudicial and damaging;
14 8. 18 USC 1513. Retaliation Against Witnesses. As to Nelson, this law is applicable in
various ways to be augmented in discovery with respect to Foget, Aveggios soil testing technician,
15
whose name is in the files, and Hoyos and HER testing technician, among other witnesses.
16
There is no question that additional federal predicate acts will be developed during discovery
17
as Nelson and SHN struggle to deny, LIE ABOUT under penalty of imprisonment, and generally
18
cover-up their criminal conspiracy involving Gans RICO racketeering enterprise, as alleged above.
19
The exact conversations, dates, employees and means of communication between Gans
20
extortion racketeering enterprise and SHN are yet to be fully discovered, however it is clear that
21 Gans/Ferriman (the many other connections alleged below) and their collusive conspiratorial RICO
22 associates named above did reach Nelson and totally intimidated and deleteriously influenced him
23 to prejudice Remington and all but destroy his contamination case.
24 Foget was 110% on-board here as was Nelson through at least December, 2012 but Gans
25 somehow cleverly poisoned Nelson during the next 18 months, and it will now take considerable
26 written and oral discovery from the above six (6+) named workers (and more likely) to prove these
27 allegations, and complete the causal chain fully. However, we will do just that before trial, at trial,
or both.
28

194
The bottom line here now is that Gans and Ferriman have undermined Aveggios credibility
1
and reputation, irreparably poisoned Nelsons mind against Remingtons case and the integrity of
2
all the excellent work that several SHN employees have done here for years, and also destroyed
3
Fogets confidence, ability and enthusiastic desire to advocate, explain and backup Aveggios work.
4
Mitchell attorneys have a long-reach into most local governments, as alluded to above, and that also
5 includes the bogus allegations they made to the 2009-13 federal court and to Nelson about:
6 Remington or actually AVEGGIO since he was one of the personal SHN testers, tampering with
7 evidence, (how or by whom is unclear); spiking the ground with hydrocarbons and creating
8 artificial conditions on the property, presumably by either Remington, Aveggio, Foget , the SHN
9 testing technician, or all of them, Etc.?
10 Gans can be very deceptive, convincing and apparently influential, and here he must have
11 seemed quite or even very sincere, almost honest, and whatever he did he was obviously quite
persuasive to Nelson. In any case Gans improperly influenced Nelson causing him to prejudice and
12
seriously damage Remington, by removing Foget from his trial witness list, when Foget Remington
13
had at that time.
14
Alternatively, Gans just went more directly and corruptly to Nelson with either a bribe,
15
undoubtably promises of substantial future work resulting in huge SHN profits, threats, or some
16
sort of intimidation, extortion, or future legal exposure? But, in any event Nelson in the RICO
17 enterprise together colluded in some sort of obstruction of justice, witness tampering of Mike
18 Foget, at a minimum, all of which nearly destroyed Remingtons whole case, simultaneously,
19 gravely damaging Remington and causing him extreme intentional emotional distress, among other
20 things, as a result.
21 The full and true story is yet to be determined from Nelsons, Ferrimans, Gans and Fogets
22 upcoming depositions, plus probably some of the other testers named above that have already been
23 implicated by Ms. Hoyos and others.
7. The Jeff Nelson timeline in this case, for which Remington has a very complete files,
24
chronological business record notebooks and many related phone records and written documents.
25
a. From 2009-2012: Aveggio was hired, trained, visited the contaminated sites repeatedly,
26
investigated all aspects of same and did all of the soil, asbestos and water tests that he had
27
recommended, the last group of which were completed over two days on August 1-2, 2011.
28
Following those tests, Aveggio determined in writing that a grave imminent threat to health and
the environment existed from the asbestos and related contaminates existing in soils, and the
195
numerous types of hydrocarbons and infectious bacteria absorbed into and flowing in waters below
1
Mathsons dump and into Remington Creek.
2
b. In January 2012, Aveggio died, very prematurely and very unexpectedly.
3
c. On July 12, 2012, Mike Foget agreed to fill-in for his deceased friend Aveggio and: Finish
4
his work; Study it and learn everything that he did or said in all his declarations and depositions;
5
advocate them at trial; and be Remingtons sole environmental engineering expert trial witness
6
through all appeals, and through as many trials as it took to resolve these disputes.
7
d. During 2012-14, Remington provided Foget with four (4) status updates by email and phone
8
messages, so there never was a time when SHN was uninformed about what was happening here,
9 for very long.
10
e. However, during that period and specifically after April 2013 but before August 2014, Gans
11 communicated with SHN and ultimately with Jeff Nelson through the various direct and circuitous
12 methods alluded to herein. Nelson therefore formally became a part of Gans extortive RICO
13 racketeering enterprise during that period, and still remains an important member, and hence a
14 RICO defendant.
15 f. After learning from Foget that Nelson was having some problems with their continued
16 representation of Remington as his sole advocacy environmental trial expert, Remington in
17 somewhat of a state of shock, spoke to Nelson on the phone on August 25, 2014 for about an hour.
18 Unfortunately, Remington could not convince him to change his mind at all, because by that
19 time he had obviously come 100% under Gans corrupt influence and financial incentives, which
Remington clearly could not match.
20
g. On August 27, 2014 Remington sent a lengthy letter to Nelson expressing his concern and
21
explaining the numerous problems and damages Nelsons unexpected and unacceptable decision
22
was causing Remington and the Burl Tree.
23
h. Simultaneously, on August 26, 2014, and crossing in the mail, Nelson said his abrogation
24
letter which unilaterally Terminated the Litigation Services and expert environmental trial
25
witness agreement between Remington and SHN.
26
i. On October 5, 2015 Remington sent his last comprehensive letter to SHN about this dispute
27
which listed and explained his damages of at least in the $39,000 range and ultimately likely to be
28 more than that.

196
j. The disputing parties last communication in this regard was a lawyers letter dated October
1
8, 2015 from Stokes, Hammer, Kaufman and Kirk, LLP, sign by a Jason Eads in which they
2
rejected all of Remingtons requests, demands and refused to amicably resolve this dispute. They
3
did not even offer the simplest and most basic refund, which any legitimate business would do in a
4
comparable situation, so now face fines, possible imprisonment and/or treble damages in any event,
5 for falling under Gans RICO influences.
6
8. How did Nelson violate the RICO statutes?
7 Many of the violations have been alluded to above, Under Gans and/or elsewhere in this
8 section and elsewhere in this document. Additional written discovery and depositions are also
9 needed to fill in all the gaps of knowledge and motivation involved here. However, we also already
10 have considerable evidence and several witnesses that tie Nelson in with the Gans RICO enterprise
11 and restricting the critical time to approximately a year between Summer 2013 and Summer 2014
12 helps immeasurably.
13 Reasonable time and space restrictions in this document, confidentiality, and prudent trial
tactics and strategy do not permit a complete presentation of everything that is now known, but is
14
a substantial part of the evidence that we now have, and enough for defendants to know what they
15
are being charged here with, which now includes:
16
a. Rather obviously, Gans played upon the fear that Remington would lose this litigation
17
and never pay Foget or SHN for the considerable work that was now projected. Foget had to be
18 brought up to speed and there was initially a small question as to whether SHN or Remington was
19 going to pay for that training and file review time. Remington thought the problem had been
20 worked out in about November 2012 because Foget said he was already familiar with the file, knew
21 already what Aveggio had testified to and hence no expensive substantial additional paid training
22 was going to be needed.
23 b. In August 2011 and thereafter, Gans, Ferriman and some of his other experts falsely
24 claimed that Aveggios comprehensive HC water testing results done on August 1-2, 2011 were
bogus, fraudulent, and involved spiked samples (which term was never accurately defined),
25
possibly involved irregular local north coast laboratory procedures, and probably other problems
26
that were never made clear. Simply put, without repeating 50-pages of the federal Protective Order
27
motion, Summary Judgment motions and numerous other later procedural and appellate motions,
28
apparently Gans did not like the results of Aveggios tests and so he declared that something
mustve been wrong with those tests. They had no idea what that might be, had no actual evidence
197
the base any suspicions on, so they just made up a bunch of scientific gibberish that endeavored to
1
exonerate Mathson and the other defendants. Generally, Aveggios 2011 testing showed that there
2
were hydrocarbons and raw sewage in the water seeping below Mathsons' dump; and, that was
3
hardly surprising because for many years any visitor to the sites, including every time defendants
4
experts including Gans himself visited, they could all immediately and easily see and smell
5 hydrocarbons and sewage in the waters in the swamp, and all across the downhill side of Mathsons
6 dump. There was also always a lot of other debris and hazardous wastes to see, but that was not
7 specifically what Gans was worried about in August 2011, aside from the asbestos, which is also
8 always an issue.
9 c. The ramifications of Aveggios August 2011 testing became quite widespread, including its
10 strong influences in the 2009 federal case, but what is probably more relevant here is how
11 Ferriman, Gans and the lower level hydrocarbon testers at Blue Rock environmental, LACO
engineering, SHN engineering and the county actual tester who work for Maje Hoyos, put all this
12
together in a conspiracy which ultimately intimidated and corruptly influenced Nelson causing him
13
to withdrawal from his contractual obligations and associations with Remington. The exact
14
conversations and the exact days involved will need to be determined from depositions, but what is
15
now known is that Nelson somehow was corruptly, improperly and also wrongfully influenced by
16 Gans to disassociate himself from his long- time friend and very trusted associate, Aveggio and then
17 (most prejudicially) further prevent Foget from getting deeper involved in all this supposed and
18 imaginary corruption and potential scandal that was fictionally written and then promoted by
19 Gans RICO enterprise.
20 To make that decision, Nelson had to walk-away from another $15-$30,000 of Remingtons
21 money that Foget would have potentially made as an expert trial witness, however Gans apparently
22 convinced Nelson that SHN would never see a penny from Remington, which all is very surprising,
illogical and stupid, since Remington always paid every penny billed by SHN immediately,
23
promptly and without ever a complaint. However Gans is a very adept, convincing and charismatic
24
salesman and he very completely Sold and fully corrupted Nelson during the cited time-frame,
25
above. Nevertheless, fundamentally this court needs to consider: why would a mercenary and
26
unprincipled business executive like Jeff Nelson walk away from a certain 15-$30,000 of trial
27 expert fees at approximately double the experts normal SHN salary? When that question is
28 answered, the culpability of Nelson and his implication with the RICO enterprise will become clear
and also proven.
198
d. There are many other factors involved here which Gans obviously used to convince Nelson
1
to back-out of his solemn common-law handshake, and one mans word to another agreement and
2
legal written contract, backing all that up, to permit Foget (and Aveggio previously) to represent
3
Remington through these contamination trials. For example, Gans is known to have always
4
misrepresented the federal magistrates findings at every opportunity, the same way he always
5 misrepresented said magistrates summary judgment decision and ultimately the Ninth Circuits
6 sustaining of that irregular and technically based decision. Both of those decisions were based
7 simply and only upon a single technical and unfortunate Pro Pers federal Rule 26 expert disclosure
8 error, and Remingtons failure to provide an expert report for Aveggio, for numerous obvious and
9 could reasons, which would take another hundred pages to explain here, and has already been done
10 elsewhere. Again, simply put Remington made a simple, innocent and good-faith expert disclosure
error, however Gans misrepresented that innocent basis for all the negative federal decisions against
11
a Remington, and argued that Remingtons and Aveggios imaginary corruption was what decided
12
of the federal cases. Without any detailed explanation or rebuttals from Remington, which rebuttals
13
and/or explanations, obviously were not possible in Gans secret enterprises conversations with
14
Jeff Nelson, over trying to get Foget permanently out of Remingtons case, Nelsons decision was
15 apparently relatively easy. Inferrentially, but still requiring discovery, Nelson decided that there
16 were financial risks and perhaps reputational risks of remaining associated with Remingtons case
17 and therefore he opted to go with the big money and the other huge financial inducements, which
18 Gans could offer over the long run. Whether Gans inducements, suspected bribes or related
19 financial advantages, extortion, coercion and/or other arguments used, were simply a common
20 short-term bribe or something more subtle, like the promise of using SHN in future cases as
experts, or a credible promise to provide SHN with $10-20,000 of future legal services, we just
21
dont know yet.
22
All that we do know so far is that Gans induced Nelson with some powerful arguments to
23
break an inviable contract to provide Fogets expert environmental trial advocacy services, at our
24
imminent upcoming trials (potentially only 2-3 weeks away), but which Nelson apparently was
25
easily able to break when he weighed what Gans had to offer in comparison.
26
e. Actually, at that very time, Gans RICO enterprise was looking for another
27 environmental expert themselves, because the Blue Rock firms experts had all been discredited and
28 remained so today. Probably Gans considered using Foget themselves, and obviously received
Nelsons blessing about that, but presumably Nelsons lawyers or other advisors suggested that
199
would be a bad idea. Meanwhile, for the rather obvious reasons which Remington has written
1
herein in regards to all of the enterprises current environmental experts, Gans decided to go with
2
their new expert from Oregon named Hillyard, after presumably weighing the pros and cons of the
3
two, plus the scores of other relevant factors alluded to herein.
4
f. Extortion and shakedown of Remington by Nelson.
5
During Remingtons August 2014 conversation with Nelson there was an unresolved
6
undertone about who would get Foget fully up-to-speed for trial the way that Aveggio had been.
7 Remington had spent about $40,000 of his own time and money working with Aveggio alone and
8 Remington had hoped that SHN would respect that and permit Foget to spend a few hours of SHNs
9 time to review Aveggios file and learn what he had said in his two depositions. That issue was
10 never fully resolved, however one alternative possible inference in the letters and over the phone
11 was that Nelson had been improperly influenced by Gans, and therefore may have been convinced
12 or believed that Remington was perhaps too poor to pay them for Fogets future services.
Remington has no doubt today that had Remington agreed to pay Nelson another $9-$14,000
13
upfront to get Foget fully up-to-speed on Aveggios testing and complete file then Nelson might
14
have ignored Gans offers and made a different decision. We dont really know today exactly what
15
was in Nelsons mind or what he might have done had Remington offered a larger bribe than what
16
Gans was paying.
17 What is rather clear without further discovery is that Nelson, on behalf of the enterprise
18 inferentially engaged in attempting to shake-down Remington for another $10-$15,000 of training,
19 trial expenses and additional testing costs. Although considerable more discovery is needed in these
20 areas, it is true that we probably wouldve done more SHN tests except for Judge Reinholtsens
21 illegitimate refusal to allow any, despite massive changes in the dumpsites for 6-7 years of waiting
22 for trial. He said we had to just use Aveggios prior and solid work, which in retrospect seemed like
one of the first signs of serious prejudicial bias against Remington as early as late 2015, when said
23
judges neutrality first appeared to be possibly in question. But, our evidence now shows that,
24
Nelson wanted more testing, more money, more security and apparently less risk and involvement
25
with Remingtons case, after he had agreed to join the other side.
26
There are many other details here too numerous to enumerate all of them, however, without
27 limitation: Gans is known to have informed Nelson that Remington was going to lose this case BIG
28 as based on the federal decisions; that when Remington did lose the case HE would not be paying
SHN because, a) He didnt have the money and b) because Remington owed defendants $12,000
200
already and after the next cases they were planning to sue Remington for malicious prosecution
1
punitive damages and many other costs which were all intended towards putting Remington into
2
bankruptcy; and, in any event since Remington would be therefore very unhappy with SHN and
3
also would not have any money, SHN would not be getting paid their last $20-30,000 for their trial
4
services. Undoubtably, Gans also added for additional false and deceitful impact, as his basic nature
5 forces him to do nothing less, that Remington was so litigious that he would also sue SHN for
6 retaliatory damages, in effect blame them for his loss, and ultimately cost SHN many times the
7 large contractually due sums which Remington had paid them for several years.
8 Therefore, both Gans and Nelson would appear to be guilty of multiple predicate acts
9 involved in that situation. Exactly who bribed and extorted whom, and in what order and on what
10 dates remains to be fully discovered in the appropriate depositions. Remington asserts today that
Nelson cooperated with and acted as an accessory to Gans Rico enterprise, during the 2012-14
11
period cited, and also obviously since then.
12
g. 18 USC 1505 was violated by Nelson by corruptly obstructing the proceedings of the
13
state court by removing Remingtons sole environmental expert, Foget, only two weeks before a
14
possible projected state trial in September 2014.
15
Under 18 USC 1515 (b) the above term corruptly means acting with an improper
16
purpose, personally or by influencing another, including making a false or misleading
17 statement, or withholding, concealing, altering or destroying other information.
18 Specifically here, Nelson violated 1505 by corruptly persuading Foget to refuse to testify
19 by improperly influencing and ordering him to comply with his essentially unlawful master-servant
20 orders, and in doing so Nelson acted with improper purposes towards his contractee Remington,
21 and also towards his employees Foget and Aveggios memory and legacy.
22 In communicating with Remington, Nelson withheld his contacts with and influence by Gans
23 and also withheld the significant low-level testing technicians conspiracy between the several
24 companies and governmental departments described above. That conspiracy emanated originally
from Gans and his orders were issued through Plotz and Ferriman, which quickly resulted in
25
prejudicially removing all of Remingtons Eureka environmental experts, and also succeeded in
26
prevented any SHN representatives from advocating or explaining Aveggios work, authenticating
27
his hand-writing as needed for his imminent threat, August 2011 hand-written notes, or even from
28
bringing in his actual testers to authenticate the original SHN January, 2011 tests.

201
h. 18 USC 1503, et seq.; 1512-13; 1515, etc. As specifically related to witness tampering
1
and witnessed retaliation, those federal laws were all violated by Nelson as follows:
2
As defined in 1515: Nelson made false and misleading statements to Remington while
3
withholding all relevant and crucial information from Remington about the removal of Foget and
4
about the unilateral abrogation of our personal trial witness service contract, in violation of the
5
above federal laws. Under 1515 (3),the term misleading conduct means:
6
(A) Knowingly making a false statement;
7
8 (B) Intentionally omitting information from a statement and thereby causing a portion of
such statement to be misleading, intentionally concealing a material fact, and thereby creating a
9
false impression by such statement;
10
11 (C) With intent to mislead, knowingly submitting or inviting reliance on a writing or
recording that is false, forged, altered or otherwise lacking in authenticity;
12
13 (D) With intent to mislead, knowingly submitting or inviting reliance on a sample, specimen,
14 test, map or other object that is misleading in a material respect; or

15 (E) Knowingly using a trick, scheme or device with intent to mislead;
16 Nelson employed all of those cited fraudulent and misleading devices against Remington with
17 collusion, planning and legal reassurance from Gans, specifically as related to violations of (A),
18 (B), (D) and (E).
19
i. 18 USC 201, Bribery. Gans RICO enterprise improperly influenced and/or effectively
20 bribed Nelson directly or indirectly with the promise of something of great value related to future
21 environmental consulting business needs, in this or in their next case, or perhaps Gans offered free
22 legal consultations with an open-ended value. Whatever bribe was offered, we will discover it or
23 endeavor to send someone to prison while they lie about it in an attempt to cover-it-all-up. Since,
24 very obviously money talks to Nelson and thats apparently all that is concerned with, Remington
25 therefore has no doubt that he could have executed a reverse-bribe of some sort when he spoke to
Nelson in August 2014 with a payment up-front of $10,000 to 50,000. SOME presently unknown
26
dollar amount would have absolutely gotten Foget back into the case, we just dont know what
27
bribery sum would have influenced Nelson at that time, and got the job done. But, we expect to
28
find out.

202
There is little doubt that Gans introduced the specter of SHNs not getting paid for future work
1
if Foget remained in the case as Remingtons testifying expert as had been planned and agreed to,
2
or alternatively, SHN was offered for greater amount of money to abandon Remington and join-up
3
with the RICO racket.
4
j. 18 USC 1341. Mail Fraud, violations of California B & PC 17, 200, et seq); and
5
18 USC 1343. Wire Fraud, including internet, email and phone.
6
By participating in Gans RICO enterprise as alleged, it is believed that future discovered
7
documentary evidence, emails, notes of personal meetings and phone records from Foget and
8
Nelson will yield plentiful violations of the above federal predicate acts, so Remington will wait
9 patiently until that time. Obviously, during the first major revision of this document therell be a
10 huge amount of new facts to add and repetitive comments here to delete, when this entire document
11 can be read as a paper copy, because as noted elsewhere right now it cannot be easily read, edited or
12 scrolled to on a computer, using LibreOffice. That program is being used because Word 2011 is at
13 least five times more unstable with the advanced transcription systems being used by plaintiff here
14 now.
15 k. 18 USC 1503. Obstruction of Justice. Nelson has no noticeable honest scruples or ethics,
16 and unfortunately his environmental expert trial services are obviously available to the highest
17 bidder, wherein, what actually happened here was that Remington just lost out to billionaire Allied
18 Insurance with their unlimited funds to litigate and/or bribe with here. A few examples of that
19 include, without limitation:
20 1) Under Gans directions and inducements, Nelson destroyed Remingtons case by removing
all competent Eureka experts, violated a reasonable and legitimate litigation support agreement and
21
inviolable contract, which seriously damaged Remington only a few weeks before an expected jury
22
trial. Nelson even further conspired against Remington and encouraged other competitors, such as
23
LACO Engineering to go against Remington.
24
2) By accepting bribery money or other corrupt influence or inducements from Gans, Nelson
25
also fraudulently violated the state and federal laws cited here related to obstruction of justice,
26
witness tampering, extortion and bribery, etc.
27 3) Therefore, Gans RICO objectives were fully satisfied by Nelson. Aveggio was removed by
28 luck, but then his replacement Foget was fully eliminated and then Aveggios brilliant work itself

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was completely emasculated by Gans further influence over Nelson to prevent Foget or anyone
1
from even reading Aveggios deposition and declarations. Later, after that, Gans further improperly
2
influenced the state court to bar any use at all of Aveggios work no matter who it was presented by.
3
That left Remington in an untenable position, which must be appealed at the next opportunity
4
because Remingtons entire case, was built on Aveggios total body of work and the court further
5 denied Remingtons motion to allow Dr. McEdwards to do some of the zone testing. Therefore,
6 Remington must rely on Aveggios testing, which has essentially been barred from the case, which
7 is obviously unjust and untenable. Either we use Aveggios tests or we need to do new ones in the
8 interests of justice.
9 4) Finally, Nelson apparently ordered Foget not to return Remingtons calls or even to meet
10 with him about this, which confirms their overall corrupt, RICO racketeering and generally
indefensible actions, which they have consistently refused to ever fully discuss.
11
12 j. 18 USC 1512. WITNESS TAMPERING, by Nelson but under Gans enterprises
13 influence and control.

14 Without getting completely lost in the weeds here, It is relevant that Gans improperly and
15 fraudulently attempted very strenuously to depose Foget in fall 2015 knowing full-well that he had
16 been removed by Nelson, and would never be allowed to appear to even read Aveggios
17 depositions, and further he had been officially de-designated by Remington in fall 2015. What
18 Gans exact improper tactics were for two months and WHY he was doing that and trying to trick
19 Remington into losing all his environmental experts, has been discussed and complained of
20 elsewhere. Since Gans and Plotz already fully understand their corrupt subterfuge and related
21 extortive RICO enterprise activity and improper emotional and other fear-inducing pressures
22 exerted upon Remington in this area, Remington will skip the several pages it would take to
23 explain all that here. During discovery involving the above RICO leadership and others, Remington
24 will pursue those significant issues in written and oral discovery, and update the additionally learn
25 facts in his next amended RICO statement.
26 Gans was obviously working-with and coordinating closely with Nelson in that deposition
27 matter, quite possibly hoping to trap Remington into false sworn testimony or to otherwise
28 prejudice his case, in other ways, all of which failed. These issues will be of considerable
importance in Nelson and Fogets depositions, however.
204
1 k. 42 USC 1983, Miscellaneous other actionable deprivations of Remingtons rights by
2 Nelson.
3 As discussed above, Nelson violated Remingtons civil rights here as described and also
4 violated California Business and Professions Code 17, 200 also as alleged above.
5 As part of Gans criminal and civil RICO enterprise, Nelson unlawfully, willfully and
6 fraudulently breached the services contract with Remington and thus he and SHN are guilty of
7 improper business practices in addition to tortful breach of contract, all of which tortful acts
8 seriously damaged Remington and the Burl Tree, and will be redressed BOTH here, under RICO,
9 and in various other state proceedings as required. During the next few years of intensive discovery
10 here, many more violations of Remington civil rights are anticipated to be discovered.
11
12 2K. Julie McBride is Gans longtime secretary, legal assistant, researcher and
13 close confidant.
14 No one on earth really knows about this criminal racketeering enterprise any better than she
15 does or about Gans true corrupt nature, lack of scruples and absence of any proper ethics. She has
16 seen the coaching, invited in the witnesses to be coached, made small-talk with most of the
17 conspirators cited here and obviously understands the true evil nature of what Gans is doing here in
18 this case and probably in all his cases. Inferentially, she knows Gans better than he knows himself.
19 McBride knows everything corrupt or criminal that goes on there, or should know if and
20 probably when she tries to claim ignorance or stupidity. However, over many years we have
21 established that she is not just some dumb bimbo or secretary-receptionist hired only for her good
22 looks, or coffee-making abilities. What we DO know about her so far is that she is not just a typist
23 and word-processor, but is a qualified legal researcher, Executive Assistant and intellectual confidant
24 to Gans, and for all we know now before her deposition, she may be the one with the big balls that is
25 encouraging him to win at any cost, and may share equal responsibility with him for their criminal
26 acts. Until substantial discovery has been successfully concluded, we cannot discount the fact that she
27 might be just as powerful and evil mastermind in all these cases as Linda Lawrence is in Sacramento.
28 After Plotz perhaps, she would be the next best corrupt, named enterprise defendant for the
federal civil or criminal authorities to target, and Remington himself intends to target and depose
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1 her federally, VERY EARLY, at the proper time, once more written Discovered detail has been
2 gathered, understood and planned-around. Obviously Gans cannot let her tell the truth, so we
3 can now expect to have World War III and World War IV in Gans attempting to prevent her, as well
4 as himself and all the others named herein, from being deposed at all. Remington will need to
5 design a standard form for motions to compel in this case. McBride here is not just a "secretary"
6 who gets the coffee and doughnuts, and at a minimum she is Gans administrative and legal
7 assistant and in all probability is also Gans CEO when it comes to enterprise business, coordinating
8 all its affairs, in keeping everybody out of trouble. Will McBride lie effectively for Gans and will
9 he be able to coach her to lie effectively in federal court the way his state witnesses did, or will
10 justice, some minor vestige of humanity and/or honest scruples plus some guilt on her part interfere
11 with and perhaps impede all of that, when the possibility of doing prison time for the perjury
12 becomes a real possibility? It would seem that lying in federal court with the possibility of prison
13 time being the penalty would be unpleasant, nerve-racking and get very old, very fast. However,
14 happily thats not Remingtons problem but it sure is a big problem to all of Gans RICO witnesses.
15 Remington has had considerable experience with various so-called "secretaries" and more of
16 them than you think are really CEOs and corporate presidents with fancy hairdos in skirts. For
17 example in Remingtons Spielberg case, Spielberg's secretary Bonnie Curtis spoke eloquently and
18 completely for him in the 1990s and rightfully also went on to become a full-fledged movie
19 producer of $100 million films. She was so important, and impossibly well-guarded, that
20 Remingtons Los Angeles process server was unable to serve her in 30 days of attempts because she
21 was just too important and well-protected to get through to. As a result, due to what she had
22 promised Remington and due to the fact that Remington could never communicate with her or get
23 any written document or deposition from her of any any kind, that cost Remington a multimillion
24 dollar case. Secretaries can be important, and in this case Bonnie Curtis was much smarter and
25 much more powerful than Gans could ever hope to be, and probably McBride also.
26 Whether McBride will ever produce a million-dollar film is unknown, but probably she
27 could and obviously she's not just some dump Bimbo, which they will now obviously attempt to
28 portray her as. Whether she's the evil mastermind pushing Gans into worse and more serious federal
crimes each month with possible prison terms up to 20 years, is not yet known, but it will be.
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1 More specifically: Remington has spoken to or received direct communications from Ms.
2 McBride several times per year for eight years, and she can act independently of Gans, most
3 recently in August 2016 when she deceitfully explained to Remington, by email, the purportedly
4 TWO alternatives for him to consider if Judge Reinholtsen were disqualified. She explained that
5 under CCP 170.3 (c) (5) Remington had two judges to consider to preside over Judge
6 Reinholtsens possible disqualification, EITHER Judges Heinrichs and Wilson.
7 BUT, understanding the corrupt source of the information, Remington quickly researched
8 and thereafter concluded that there were more than just the two alternatives which Gans and
9 McBride wanted Remington to choose between, and that the only fair, honest and possibly
10 unbiased solution was actually a third unstated alternative. That was to find an independent visiting
11 or down south judge that did not eat lunch with and socialize every day with Judge Reinholtsen,
12 and ultimately that obvious alternative was selected and carried out.
13 McBride is believed to be ALSO thoroughly corrupt which is obviously needed to work full-
14 time for 15 or more years for a long-time mafia-like racketeering leader. How could she not be?
15 Remington has had numerous secretaries and personal or administrative assistants and by necessity
16 they have to understand the work going on, especially if it is corrupt, just as well as the big boss.
17 Whether she issued unlawful orders or not is presently unknown, however she was a smart
18 woman, right in the middle of a criminal racketeering gang and had to been aware of what was
19 going on. Would the godfathers personal secretary transcribing notes in the middle of meetings be
20 oblivious of the basic criminal nature of the crime family? That will be one for the jury perhaps.
21 She helped to plan, write and type every unlawful and unethical detail presumably did the
22 research regarding each and every federal predicate act of mail fraud, and colluded and participated
23 in such specifically enumerated frauds as how to plagiarize a federal judges orders without going to
24 jail, and inferentially she edited all, or perhaps even individually authored many of Gans unpleasant,
25 threatening, mischaracterized, fraudulent and often extortive writings for his signature. It now seems
26 beyond likely that she gave him infinite inspiration and probably reminded him, with her superb
27 memory, of the hundreds of past relevant nasty and false accusations against Remington that she has
28 been typing and copying for many years, from many months or years previously, to add into the

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1 current documents. Someone there certainly has a good memory and it probably is not Plotz who has
2 not even been there three (3) years yet.
3 Inferentially, since she was Gans chief researcher, she probably copied the repetitive portions
4 of Gans old false accusations into the current documents, because someone did that.
5 McBride has clearly made several hundred thousand dollars salary since these cases began in
6 2006 and arguably something like half of all of her hours since 2008, or more, have been devoted to
7 various illicit defensive frauds perpetrated against Remington in these cases, including the clearly
8 stated RICO objectives, below, which the enterprise focused-on after 2011-12.
9 At the very least, McBride is a full-time, card-carrying knowledgeable member of the inner
10 circle of Gans RICO racketeering enterprise and potentially is its number two in command,
11 above Brisso and Plotz.
12 Obviously, whatever happens to Gans should also happen to McBride.
13
14 2K. Ted Kloeppel, another Mitchell firm member, apparently of a slower, LESS-
15 BUSY or lower echelon, that fills-in a lot at hearings for other attorneys who are on vacation, and
16 always seems to have time to fill-in for Gans, Brisso or Plotz in these cases.
17 Kloeppel, although somewhat of a borderline figure here, is in January 2017 now believed to
18 be an active and corrupt RICO enterprise member, partly because he probably knows exactly
19 what Gans is doing and how he is deceitfully and corruptly doing it.
20 Kloeppel has a rather innocent-seeming, honest-looking demeanor, however so do all of
21 the crooked Mitchell firm attorneys. His name appears in these case documents with some
22 regularity and If Kloppell really does not know what Gans is presently doing, he should know,
23 should have known, and he obviously does know now. If he were really a good honest California
24 officer of the court, he would now come forward and talk to all of his crooked associates and
25 see if they can figure-out some way to end all this before they spent five years defending it and then
26 going to prison. He is presently believed to be one of the cooler heads, but not necessarily more
27 honest than the rest of them because they are all good at the false pretenses of appearing to be
28 ordinary ethical small-town attorneys.

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1 Kloeppel is another attorney in Gans corrupt law firm on the fringes of a Mafia family-like
2 criminal enterprise. He almost avoided RICO defendant status here because of his benign manner
3 and cursory appearances, however after several months of researching and drafting these
4 documents his name appeared too often especially in older discovery documents in this case, such
5 as the drafting of deceitful special interrogatories, some of which have now become the basis of
6 RICO conspiracy and fraud. He works there, he knows Gans WELL, and therefore he has to know
7 about Gans lack of ethics, laziness and inability to function at the highest level in Californias legal
8 system. As an attorney with an office a few feet from Gans he is held to a higher standard than
9 most, and he will certainly be investigated for complicity and what it does know about this
10 racketeering enterprise or, as above, he obviously should have known. If Remington understands
11 Gans and knows about all of his illicit criminal activity, then it is more than logical to assume that
12 Kloeppel also knows now, and has known about it for many years, but kept silent.
13 Maybe he can convince civil or criminal investigatory authorities that he is dumb, naive
14 and/or innocent, however after thorough analysis and consideration, it seems obvious to
15 Remington that Kloeppel should now have to come forward with what he knows and exonerate
16 himself first, because right now he appears to be guilty before he is proven innocent. In other
17 words, why not now come forward and tell the truth right now, before depositions and motions to
18 compel, and prove your innocence, if that is in fact the case. Alternatively, it should not take a pro
19 per to present the unpleasant risks and possible alternatives of attempting to lie-away, and maybe
20 get dismissed a RICO case which we all know has absolute and impregnable merit, and which
21 during the most basic and obvious discovery could send numerous perjuring witnesses to prison if
22 Remington is allowed to pursue sworn discovery, as would appear to be allowed after making this
23 initially meritorious and irrefutable showing.
24 If, and WHEN, Gans eventually and inevitably goes down here, most likely when some lower-
25 level enterprise member gets scared and decides that they would rather stay home with their
26 children than possibly go to prison on Gans behalf, Mr. Kloeppel, who has never said anything
27 substantive in these cases, that Remington can recall anyway, when he made appearances for his
28 fellow law partners, should still have to fully explain himself under oath for many hours, to the
district attorneys investigators. For example, after reading or skimming these RICO case
209
1 documents, if Kloeppel was a real attorney with real old-fashioned attorney ethics (as he portrays
2 himself and infers with this slow methodical speech), he would immediately walk-over the 30-feet
3 to Gans office and cross-examine Gans, Brisso and Plotz and determine what the REAL truth is
4 here in a few minutes. At that time he could come forward and implicate his fellow enterprise
5 members, start some sort of a plea bargain, but (or) most likely he will keep his mouth shut
6 about what he knows to be true, until he is implicated by someone else, or until tied to a predicate
7 act by a witness or a writing. Remington has recently seen his name unexpectedly on some case
8 documents, but has not yet gone through them all as to authorships.
9 Kloeppel is by no means the worst of the RICO crooked attorneys named herein, however if
10 Remington was looking for a good honest ethical attorney to pursue a moral issue or ethical
11 violation against someone, he could not look Kloeppel in the eye in good conscience, and know that
12 he was going to get good representation. In other words, to Remington, Kloeppel is either
13 disingenuous and corrupt in his knowledge of the RICO enterprise or quite unperceptive and/or
14 rather stupid. Of the two alternatives, Remington presently believes that the latter is the most
15 unlikely.
16 Although perhaps just an enterprise "soldier", if Kloeppel is still there, hanging-around
17 obliviously, innocuously and innocently on the Mitchell firms premises, when the Federal or
18 County agents come to arrest the primary enterprise members, Kloppell will then have to prove his
19 innocence, not the other way around. How will he do that?
20 Kloppell plays the nice, pleasant, friendly and somewhat dumb guy very convincingly,
21 however he is hereby put on notice that he is in the middle of a criminal enterprise, like Hitlers
22 inner circle, and very soon hes going to have to prove his innocence, rather than the other way
23 around. If he has been intending to plead insanity about the corrupt crime family operating out of
24 his law offices right next to his own office, that opportunity has now been lost. At a minimum, these
25 documents should all be read by all Mitchell firm lawyers, and then they can act accordingly.
26 However, pleading ignorance and that they just had no idea there was a crime-ridden RICO
27 enterprise operating right out of 814 7th Street will not be a very effective defense after all relevant
28 courts and authorities have read and understood this document.

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1 Kloeppel has done plenty of significant, substantive work in these cases, especially back in
2 2011 on the notorious Special Interrogatories, Sets TWO and THREE, etc. He has also made
3 appearances in about a dozen hearings where he was expected to understand the cases and respond
4 to the court or Remington just as well as Gans or Brisso, and seems to have done so in at least one
5 called instance. He may know MUCH MORE than presently believed and MAY be in the RICO
6 inner leadership circle, as will be investigated, and still needs to be discovered.
7 Therefore, during January 2017 Remington elected to promote him into RICO defendant
8 status, which he could probably defend and/or defeat rather easily if he decides to tell the truth
9 about what he knows about Gans corrupt enterprise, or convincingly pleaded insanity and
actually convincingly pretend to appear to be genuinely shocked.
10
11 3. List the additional alleged wrongdoers, other than the defendants
12 listed above, and state the alleged misconduct of each wrongdoer.
13 A. Larry Kluck, Esq. of Francis Matthews and Associates law firm, is the present attorney
14 for RAO, Rich Olson, Kyle Skillings and the other likely RAO DOE defendants, presently unknown.
15 Kluck is and has been clearly under Gans full influence and total control for over two years, as
16 he gets 100% of his case documents from the Mitchell firm, and never asks Remington for anything
17 when we see each other every few weeks or so. Evidently he gets all copies of Remingtons documents
18 easily and better, straight from Gans.
19 Essentially by definition therefore, Kluck IS NOW IN Gans RICO enterprise, because he is
fully under Gans control, getting 100% of his information about Remington in these cases through
20
Gans only, plus Kluck has personally committed at least two significant listed predicate acts,
21
described herein, including below.
22
Kluck has done nothing substantive or material yet in any of these cases, except to sit there in
23
court and pretend to be interested, occasionally. That is because his case is still stayed and
24 obviously he has the utmost confidence that Gans will kick-Remingtons-ass out of court so that he
25 (Kluck) will never have to do anything here, which inferentially appears to be his preference.
26 Kluck talked to Gans at length at least twice a week in the courthouse corridors, which
27 Remington personally observed, from May through September 2016. How many other meetings
28 they had that Remington is not aware of and did not observe is unknown. However, it is doubtful
that Kluck appreciates the depths of the criminality to which Gans is leading Kluck, Olson and all
211
of the RAO defendants, but hell wake-up and get it soon enough, if he is not now fully informed
1
about the truth in these matters.
2
Also, whether Olson has honestly explained his criminal hauling, disposal and related crimes
3
in 1998-2000 (to Kluck), which crimes presumably what occurred also in many other earlier and
4
later periods at other sites, is unknown and beyond the scope of Remingtons present involvement
5 or concern.
6 Kluck has not yet bothered or harmed Remington substantially or frequently like Gans has
7 done, except in his single serious attempt to extort Remington with Hobbs Act inspired fear as
8 described above when he tested Remington, intimated that he would probably lose this case
9 against the mighty Russell Gans, and his related course of acts, amply described above. Remington
10 cannot yet allege two federal predicate acts against Kluck, and therefore is not attempting to do so
here, yet.
11
Therefore, Kluck has not yet been named as a defendant here, but almost CERTAINLY
12
will be as he is right on the edge of the hornets nest (buzzing like a possible wasp), under Gans
13
full control, and Remington would expect he will be very soon promoted to the cover of page 1 as a
14
defendant at, or prior to the time of the FAC in this case, or sooner. He again came really close to
15 getting there with his disingenuous and entirely knowingly CORRUPT Supplemental case
16 management conference statement dated January 13, 2017 for the February 17, 2017 hearing.
17 Remingtons February 13, 2017 comment number six in his declaration of Bruce Remington was:
18 Most, but not all of the background history and legal statements made by Mr. Kluck in his
19 January 13, 2017 statement are incorrect, false or deliberately misleading conjecture or wrong self-
20 serving predictions, which misstate California law in any case at best, and did not take into account
the numerous appealable errors made during 2016 in DR 080678, at worst. It is probably about
21
60:40 that DR 080678 will be appealed in the next two years, however as discussed in the 10-page
22
document and as formally ruled on behalf of Department Eight by Judge Watson in 2014,
23
DR140426 is entirely independent of DR 080678, and therefore there is no need to wait for more or
24
any actions in that case before continuing with DR140426.
25 For example, Klucks corrections in the caption about being erroneously sued as RAO
26 Construction is somewhat disingenuous, and as noted above we do use the term INC, and to me
27 construction can be abbreviated by CO, as Kluck likes to do, and RAO has been referred to as
28 RAO construction for years in these cases, and no one ever furnished any discovery
documentation to correct that, but they soon will have the opportunity to do so.
212
Additionally, Kluck deviously, unethically and wrongfully keeps referring to Costa
1
Trucking as a defendant, in a blatant and flagrant attempt to try to embarrass Remington and to
2
make him look inept and inexact. Kluck well-knows that Costa is not charged as a defendant here
3
and that his transparent and corrupt effort at confusion which he will attribute to Remington
4
eventually IS DECEITFUL AND FALSE, for reasons which were explained in detail in many other
5 case documents that are beyond the scope here. [These blatant attempts to prejudice Remington
6 with a new court in DR140426 are improper, unethical and unacceptable going forward, but are
7 also the price of admission and the required corrupt and actually the only method of operating
8 within Gans enterprise, and definitely reflects very adversely on his integrity as a disingenuous
9 zealot, and corrupt advocate. Nevertheless, the above deliberate errors and unethical advocacy
10 tactics in estate proceeding are not yet federal predicate acts, and therefore not enough to elevate
him to RICO defendant status, however that is virtually guaranteed very shortly, if he keeps that up
11
as he now must.] Gans requires nothing less than corruption and criminality, so for Kluck to
12
actually begin real work with Gans, the federal criminal result of their collaboration is very
13
inevitable. Remingtons February 13, 2017 status conference comments continued with, in
14
relevant part:
15 This court might note that in my caption here Costa trucking is not listed as a defendant.
16 Gans originated that false defendant (FRAUD) by alleging that Costa trucking was a defendant at
17 a 2014 deposition, involved in this criminal activity, but after some investigation, they were never
18 sued in this case because I reasonably concluded that the new owners of Costa Trucking were not
19 responsible for or implicated in the crimes known to have been committed by all of the named
20 defendants, plus some others that are not yet named. All of that has been well-known to all
defendants for several years, but Kluck thinks he is being cute by harping on spelling and
21
inconsequential technical and semantic errors, however sooner or later he is going to have to take
22
all of these actual substantive case issues more seriously and get into the real case facts, which
23
center upon the real criminality of his clients and the possibility that some of these RICO enterprise
24
members, not excluding himself, could eventually serve time over these criminal RICO litigatory
25 tactics.
26
B. RAOs insurer, Allstate, State Farm? or whoever they are discovered to be.
27
Olsons liability insurance will have to protect his and RAOs massive felonious 1998 trucking
28
and excavation operation on Mathsons' (and Remingtons) land and probably he has done this

213
1 elsewhere which will also probably come out in a future criminal investigation here. Remington is
2 familiar with a variety of illegal trucking hauling and dumping operations in this immediate area,
3 From about 1960-2000, and has never seen, heard of or even imagined a larger such illicit for profit
4 residential hazardous dumping and disposal operation, than the one which defendants created here
5 on these two large adjacent properties.
6 Remingtons requests and interests in these cases are simple enough to correct and/or to grant
7 and involve remediating his own damages and to be compensated for all detriment proximately
8 caused thereby, which will further involve cleaning-up the environment, the adjacent Remington
9 Creek and the Elk River tributaries it flows into. As these cases now gradually go criminal, other
10 federal or other criminal authorities are expected to have broader purposes.
11 We will of course learn the identity of Olson and RAOs insurer in the first written discovery
12 requests and with Gans at the helm, and an underutilized pretty-old Kluck following dutifully
13 along, it is hard to imagine less than another few years of legal fees incurred before anyone comes-
14 up for air or gets serious about cleaning-up this waste dump and justly resolving these cases.
15 The enormous financial power now presumed to be behind RAO, Olson, Skillings and Kluck
16 (to further augment Gans unlimited financial and personnel resources) will be interesting to
17 observe and they may want to study this RICO case, as well as Remingtons environmental claims,
18 carefully, before blindly hopping-On the Gans-Lawrence runaway train, which appears to
19 Remington to be likely heading for an imminent derailment when their brakes fail further down the
20 mountain while trying to keep their numerous 2016 SOL trial lies consistent and also to keep them
21 from becoming federal perjury allegations.
22 In other words, Allstate, State Farm, or whomever defendants insurer is, has done nothing
23 wrong yet, but probably will have by the time the court is reading all this, especially if they produce
24 a long-time personally involved zealot such as Linda Lawrence of Allied Insurance.
25 As with Gans enterprises clear objective of crushing Remington, the RAO insurer will likely
26 immediately assume that same objective, and attempt to protect their felony policyholders, so at the
27 moment, it is very hard to see how the Kluck-RAO defendants will be able to coordinate their
28 efforts with Gans and still manage to remain clean, honest, uncorrupted and fully independent of
Gans RICO conspiracy, for long.
214
1
2 C. Brian Gwinn, apparently the current head man at Blue Rock Environmental.
3 1. Gwinn is either a dishonest, corrupt and very crooked environmental investigator, or he is just
4 pretty inept and in any event highly incompetent, overall. His educational background and relevant
5 experience for this project are both just as undistinguished as his incoherent behavior was on his
6 last two hour visit here.
7 Gwinn ambled slowly around the dump sites here carrying a garden spade for more than two
8 hours, without ever digging anything noticeable everywhere that he tried, because he immediately
9 hit concrete on every attempt to dig something, just like ALL the SHN and other environmental
10 borers did. He also studied some maps while he sat in the shade for the better part of an hour, and
11 the day he was here, he seemed totally dazed and never seemed to orient himself to where he was.
12 Meanwhile the rest of us, Remington, Gans and Ferriman, investigated some of the
13 contaminated water in the lower parts of the property around the swamp area, which was what was
14 really important in July 2011,
15 2. Gwinn just sat there in the shade for a good hour and never came down to view any of the
16 significant polluted water test sites, near and flowing into the creek. Gwinns main claim to fame
17 here was his infamous Stick Test, as described elsewhere, under various subjects including: His
18 attempted destruction and obstruction of justice and evidence, Stupidity, the only contamination
19 test ever done on Remingtons land by defendants; The most Single significant contamination
20 test ever conducted here on either property in these cases; and elsewhere. Gwinn is something
21 of a joke around here, for example his useless measurements with a calibrated tape, are kind of
22 humorous and a very ignorant, because any ordinary builders tape measure or even simply pacing
23 off some of those insignificant distances measured, could have accurately estimated the distance
24 between any of the two or more unimportant points (locations) which he was attempting to
25 determine.
26 3. Gwinn is a central figure in the 2008 State cases, and so far THERE has violated several
27 federal and state laws against lying in all his declarations, but Gwinn has done NO trial perjury yet
28 and also has done no known work in the 2012-16 period relevant in this RICO action.

215
1 Gwinn is a central witness defending Gans, Mathson and the other defendants to the
2 environmental allegations alleged in this federal case, but at the moment Gwinn is playing no direct
3 part in the RICO enterprise, however that is definitely expected to change soon.
4 4. Gwinn has so far been under Gans full scientific control, and Gans is believed to have
5 written every word of every declaration which Gwinn has signed to date. Whatever Gans writes,
6 says or pays for appears to be fine to Gwinn, and he well apparently sign anything, although he
7 does write rather elaborate, almost humorous, half-page qualifications of his California under
8 penalty of perjury oath, rendering it meaningless in Remingtons opinion. To Remington, what
9 Gans expert Gwinn does amounts to bribery or pay to play, and to Remington he is merely an
10 overpaid expert whore with no scientific or mathematical credibility whatsoever.
11 5. VOLUME of the encroaching fill on Remingtons land. This is Gwinns most important
12 area and likewise he has made his most egregious errors relating to volume, and apparently all his
13 work on volume was knowingly corrupt. In other words, is explained fully below, the mathematical
14 errors which Gwinn made were far too wrong to have been simple good faith mistakes but had to of
15 been deliberate fraud crafted and written by Gans for Gwinns signature.
16 Gwinn knowingly used the VERY wrong three numbers, Length x (times) Width x Depth,
17 to determine the volume of the fill. If all three numbers are wrong, then the volume calculated by
18 Gwinn was wrong, Very wrong. Since each wrong volume component produces a multiplicative
19 error, if each component Number is wrong by 200%, then the net calculated volume would be off
20 by 800%, which is about what happened here with Gwinns calculation.
21 The problem with Gwinns calculations are the magnitude of the errors and the incriminating
22 types of errors made, which were such that no honest scientist with even a high school geometry or
23 sixth grade arithmetic education could possibly have made such errors in good faith. To Remington,
24 there is no doubt that Gwinn is not just very inept, but has to be corrupt, because he swore to false
25 volume results which he must have known are totally fallacious and not even close to the proper
26 order of magnitude. Maybe some judges with an inadequate mathematics background might
27 possibly miss the utter corruption and criminality of Gwinns errors, and would ( and in fact
28 did) give Gwinn the benefit of the doubt, and not lock him up in jail for obvious bad faith.
Remington however, is much less forgiving and having had more than 30 high-level Ivy
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1 League credit hours of Advanced Calculus, Differential Equations, Statistics, Dynamics and above
2 (as a National Sloan Scholar student in Mechanical Engineering at Cornell University, then the
3 second highest rated engineering school in the USA), is much less forgiving and believes that no
4 one with Gwinns educational background, could have possibly made such egregious errors in good
5 faith.
6 If Gwinns work is not corrupt and in fact is just innocent error, then he would have to be
7 an idiot. But, Remington has met him and interacted with him and/or his work, for quite a few
8 hours, and knows that he is not an idiot and in fact he is rather astute, very circumspect in his
9 corrupt and deliberately erroneous interpretation of such obviously fallacious parameters
10 purportedly from our experts test results, but which it is entirely inconceivable that any expert of
11 average intelligence could have relied upon. In fact he is rather astute in his corrupt and
12 deliberately erroneous interpretation of said obviously fallacious parameters in good faith, and is
13 always afraid to look Remington in the eye or talk to him, which Remington attributes to a strong
14 sense of guilt just wreaking and oozing from his body. Gwinn is definitely not happy in his
15 deceptions the way Gans is, who always jokes around in his investigations like hes having a ball
16 or at a party.
17 Maybe thats just an overly abstract way of saying that: Since Gwinn is not stupid, supposedly
18 is a scientist with some kind of experience, but claims he relied on nonsensical depth of fill
19 numbers which no one in good faith could have possibly relied upon, Remington therefore
20 concludes that Gwinn is a crook, wrote sworn reports in bad faith, and therefore committed
21 perjury in his written documents. When he repeats that under oath at trial, he will get himself into a
22 lot of trouble. When he does that in federal court that trouble will be multiplied by 100. therefore
23 for those and related reasons, Remington concluded at least a year ago that both Gwinn and
24 Ferriman are going to cut their losses here before they have to testify falsely under oath in any court
25 proceeding. We will soon know if that is true or not.
26 No expert could honestly be that stupid, and Remington does not believe that Gwinn is that
27 stupid, as he just said above. Therefore, all Remington can conclude at this point is that Gwinn is
28 very dishonest, signs reports in bad faith, which entirely frivolous and false reports must have been
(and were admittedly) written by Gans, because no credible environmental scientist that runs an
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1 environmental company and who has had graduate training in environmental science and
2 Elementary school arithmetic and plane geometry, could make the kind of errors that Gwinn made
3 and then swore to, with his odd qualified oaths, with a lot of meaningless knowledge and
4 beliefs. Therefore, Remington concludes that Gans wrote Gwinns reports, Gwinn just signed
5 them as though they were his own, so there is plenty of fraud to split between Gans and Gwinn.
6 Now that the errors and obvious scientific fraud are fully exposed, Remington is positive that
7 neither Gwinn, nor Ferriman can or will subject themselves to possible federal or state trial perjury
8 with false oral testimony at a contamination trial. That opinion has been further corroborated and
9 confirmed by the fact that neither expert made an appearance in August 2016 at the SOL trial and
10 simultaneously Gans hired another expert from Oregon, Mr. Hillyard, at considerable additional
11 expense, to fly him in, to provide defendants with a new, and as yet uncorrupted and still
12 undamaged environmental expert. But, it wont be long before he is corrupted, count on it.
13 Gwinn has other big problems here if he ever testifies at any trials. His original lengthy 130-
14 page environmental report co-authored with Ferriman was also entirely incompetent; again,
15 knowingly corrupt, and fraudulent and because it was intentionally done out-of-time. Out-of-time
16 means by definition that it was incompetent, not valid, Understated all toxicity and contamination
17 measurements and had to be done in bad faith. Yet, Gwinn, Ferriman and Gans completed it in 2010
18 and submitted it to all parties and organizations involved in these cases for many years, as the
19 ultimate encyclopedic work about contamination on both sites. Unfortunately, said report was not
20 only incompetent and fraudulent but it was specifically intended to deceive Remington, his
21 experts, all courts involved here and all the environmental watchdogs from a dozen agencies,
22 which have ever been involved here. Said report, did succeed in deceiving all of the above, and
23 still serves that purpose today as effectively as when it was fraudulently written and circulated.
24 As above, Gwinns faults calculations, wrongful conclusions an obvious bad faith corruption have
25 all been long recognized here, and he will therefore be discredited completely at any trial where he
26 appears. He is definitely a good soldier for Gans in the environmental trials, but is not yet believed
27 to be deeply involved in the RICO enterprise, but he will be. Gwinn has been arguably Gans
28 second most important witness (after Ferriman) since 2010, and as soon as he opens his mouth for a

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1 few paragraphs in a federal trial, he is expected to immediately violate several obvious predicate
2 acts.
3 That is one reason why he is given so much space here.
4 Gwinn is essentially an important RICO racketeering enterprise lieutenant, acting on behalf of
5 the Gans-family. He appears to be corrupt and without any scientific ethics and probably is willing
6 to do almost anything, except for probably not murder, because Gwinn is kind of a pussy, unlike
7 Skillings. Ferriman is the tougher one that wrestled with Remington over his camera when he tried
8 to continuously violate the last investigations ground rules which allowed photography in and
9 around the dumpsites but not anywhere and everywhere else, where they saw possibly prejudicial
10 shots that were irrelevant in every respect, to any lawsuits.
11 As soon as he begins testifying in this 2012-16+ time frame he will almost automatically start
12 implicating himself in multiple federal felonies involving Mail and Wire Fraud, Obstruction of
13 Justice, Suborning of Perjury, perjury, witness coaching and tampering, Deprivation of Remingtons
14 civil rights, money laundering, and many state fraud and other violations.
15 Therefore, although ostensibly clean Today for the respect to criminal RICO charges, if
16 Gwinn ever testifies according to Gans coaching and written scripts, it may be looking at 10-20,
17 plus fines. Specifically, if he ever swears federally or even at a state trial to the exact documents
18 which he swore to previously in spring 2011 in the state summary judgment motions and the fall
19 2011 federal summary judgment motion documents, he is expected to become instantly implicated
20 in Gans RICO enterprise. Today, is not a defendant and his function in the RICO enterprise is
21 ambiguous, obscure and possibly merely latent, but imminent.
22 D. Mark Ferriman is Gans' Enterprises principal environmental scientist and chief sampler
23 with a BA degree from an unknown Eastern College, in an irrelevant specialty. He has no other
24 relevant education, credentials, significant experience or special competency. Overall, as a witness,
25 he has no more than one quarter of the overall competency and experience of Aveggio, now dead;
26 and, Ferriman also has no more than one third of the total relevant education and experience of
27 Remingtons present environmental expert, Dr. McEdwards who holds a PhD in the relevant
28 environmental engineering fields from the University of California at Berkeley, plus substantial
related experience with asbestos and hydrocarbon contamination testing and remediation.
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1 To shorten this statement, Remington will spare all the detail on Ferriman, which like Gwinn is
2 virtually all negative, with many perjured declarations which Remington will of course prove at any
3 state or federal trial, if Ferriman has the audacity to appear.
4 If Ferriman's lies are repeated in federal court, from the 2011-12 state proceedings, we will
5 quickly get about a dozen perjury, obstruction of justice and related mail fraud predicate acts. If that
6 occurs, Remingtons trial strategy will be made much, much easier. Today, we probably have no
7 provable federal crimes in the 2012-16 period of expert activity, however, Ferriman made
8 numerous complaints, errors and frivolous and/or corrupt writings in the slightly earlier period,
9 which will now lead to federal imprisonable perjury, obstruction and related conspiratorial
10 fraud charges if he re-issues them at any trial.
11 Ferriman is notorious for lying about: 1) The twin six-inch Mathsons drainpipes which are
12 solid not perforated; 2) the fact that said drains do not drain any part of the fill whatsoever, and
13 hence are absolutely not the "perfect test case" for proving that the fill is inert and benign; 3) the
14 only water which emanates from the downhill termination of said pipes is County drinking water
15 derived from Mathsons garden hoses plus a clear spring in the area which has not just permeated
16 through 8 feet of fill; 4) the false defendant fact, obviously promulgated by Gans and the enterprise
17 and the simultaneously material mischaracterization (and LIE) that there is only one "possibly"
18 asbestos pipe on Remington's land, when Ferriman himself personally saw, stared at for 30
19 minutes, discussed with Remington and Gans, handled and then systematically personally
20 photographed at least 23 of those significant asbestos pipe samples which were visible on July
21 5, 2011; 5) the blatantly obnoxious toxic contaminated water that smells like diesel in the swampy
22 area, which is obviously, to all expert observers, not just decayed Redwood, as proven by three
23 different independent sets of tests done over a three-year period; 6) Remington's "water circulation
24 system" does not contaminate Mathson's land or Remington's land and never has and never could;
25 7) Remington's contaminated debris deposited by Mathson cannot be easily removed by a long-
26 reach Gradall from Mathsons property for $10,500; 8) his false statement that the pollution and
27 contamination on Remington's land is de minimus and not a problem if just left alone; 9) the
28 Chrysotile (60% asbestos) is no big deal and will not harm anyone or the environment; 10) the 2010
Blue Rock tests were accurate and proved that Mathsons land was pristine and not contaminated
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1 with diesel, motor oil, asphalt, asbestos and dozens of other remnants found in their borings; 11)
2 said Blue Rock tests were competent and correctly calculated at the lab, although they were a total
3 of 6-8 weeks out of holding-time and totally worthless scientifically, except as proof of deliberate
4 misrepresentation to all participants, plus fraud on the court (two courts) on Remington and on his
5 experts, all of whom reasonably relied upon Ferriman and Gwinn's signature, scientific veracity and
6 certifications.
7 D-1. Jon Kishpaugh. Kishpaugh is a charter member of a Mathson-RAO dumping conspiracy,
8 drinking, drug-using and suspected burglary (see Mickee below) Westgate gang that often
9 terrorizes Remingtons property, and has been involved in all of Remingtons complaints herein,
10 from the very beginning, in the 1990s.
11 He was a long-time polluter, contaminate or and dumper in his own right into the upper canyon
12 of "Remington Creek", which is a prominent portion of Remingtons land, and has broken-through
13 many Remington fences to keep dumping there over the years, which continues. In May 2006,
14 when he could no longer break down the 10-foot high wire fencing, even Joy Mathson reported him
15 to Remington as the dumper of a massive amount of Escallonia and related automotive debris and
16 garbage onto Remington's land. Kishpaugh just never got the message that Remington's land was not
17 a garbage dump for his own personal use.
18 After Remington had fully closed in his yard with impenetrable fences, for deer, bear and
19 scofflaws and criminal dumpers like Kishpaugh, he still kept dumping along the outside of
20 Remington's hedge in the Westgate right-of-way across from his residence. That right-of-way was
21 maintained by Remington and Kishpaughs dumping was very offensive to the entire neighborhood
22 and continued until about 2012, however it does not arise to being a federal predicate act at this
23 time and is just mentioned here as background.
24
25
26
27
28

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1 D-2. Mickee Kishpaugh19 was also seen stealing stuff and running back to her house with a
2 big plastic bag full of some kind of illicit valuables back in October, as though she were Santa
3 Claus, as alleged in the footnote, however whether it was stolen from Remingtons land and
4 damaged him or stolen from some Other neighbors property has not yet been determined.
5 However, BOTH Kishpaughs overall bad character and unreliability is confirmed by those
6 facts and when Joy Mathson is next questioned under oath, perhaps in the federal proceedings, she
7 will be grilled about what she told Remington in detail about the Escallonia dumping and
8 Kishpaughs recent denial of doing that under oath. All the defendants now want to lie about that,
9 however why Remington would want to make-up such a dumb and insignificant story if it were not
10 true, will need to be determined by someone else, at the next trials. The facts are that Remington's
11 story of that and many other related minor issues are true, and if Joy Mathson and Kishpaugh want
12 to put their credibility on the line in front of the next jury, than Remington welcomes that and will
13 prepare WELL next time. Especially for Joy Mathson who thinks of herself as a "woman of
14 integrity", credibility and great wisdom. All of which, we will soon see.
15 Discovery will soon reveal which additional predicate acts may have been committed by
16 Kishpaugh.
17 Today, obstruction of justice and perjury are Remington's complaints in the provable state and
18 federal violations from August 2016. All future trials will start their with THAT egregious and
19 blatant perjury by five defendants witnesses and will build more from that cover-up which happily
20 now they will have to attempt to continue consistently. In other words they will now half to keep
21 lying and explaining to us how they were not lying in the beginning at the 2016 trial, and therefore
22 it would follow that they still are not lying today. Treating all of that last sentence would now be
23 federal perjury untouchable by imprisonment and they may want to start out that way and then
24
25 19
Mickie Kishpaugh is also jointly involved in the Gans racketeering enterprise and is an ignominious,
26 odd character in her own right. On October 23, she was seen frantically scurrying along carrying a heavy
black plastic bag into her house at dusk, furtively looking over her shoulder like a fleeing house burglar,
27 to see if she was being watched or followed, and acted very guilty as though the bag contained a lot of
valuable stolen merchandise, from some adjacent neighbors yard. She was seen by Remington and watched
28 from the top of his hedge that night as he was doing some other work.

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1 continue on with additional further perjury about many related substantive contamination case
2 issues.
3 On October 25, 2016 local Eureka newspaper published that Kishpaughs house is in default
4 and that they owe $64,256.10 on their loan. The Kishpaughs have been financially desperate for
5 years, and that would explain what happened in August 2016 when John Kishpaugh was paid a lot
6 of money, which simply put was just a bribe from Gans, to change his testimony to falsely
7 incriminate Remington with newly created testimony that head never been mentioned in the prior
8 eight years of litigation.
9 Also in the two rather relaxed encounters that Remington has had in the last 12 years with
10 Kishpaugh, all he said was "get this case over with" as fast as you can because it's upsetting to
11 everyone, or words to that effect. Kishpaugh never said anything about how he was going to screw
12 Remington with perjured testimony, and the reason for that was that said perjured fabricated and
13 coached testimony was not even invented by Gans until late July 2016 when Gans became very
14 desperate. John Mathson knew the Kishpaughs were desperate and could be paid for their testimony
15 about anything. Kishpaugh was paid and bribed with somewhere between $1000 and $5000, which
16 money he desperately needed, in order to say anything Gans wrote, as far as the hated Remington
17 was concerned. We will prove excessive and improper monetary payments were made to the
18 Kishpaughs in or around August 2016 during federal discovery here. The Mathsons are also
19 believed to be the Kishpaughs best friends and therefore they would also say anything to benefit
20 them without even being paid for, however here Kishpaughs desperate need for money played right
21 into Gans hands.
22 Chances are good that Kishpaugh was paid by check, which we will certainly investigate,
23 discover and determine any money which the Kishpaughs received, and deposited in that timeframe.
24 Since fines and possible prison time are involved here for all, if one goes down, such as Gans for
25 example. Therefore it will be interesting to see how deep Gans, Mathson and both Kishpaughs want
26 to bury themselves in deeper here, going forward. In other words, will Mickie fully and accurately
27 back Jon Kishpaugh or will she spill "the truth" by accident? With Gans so obviously and
28 completely corrupt here over so many years, and with so many major transgressions, how many of
these enterprise members are going to go down with him when his ship soon hits the rocks of this
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1 jagged reef far out into the ocean, with no actual land or safety zone, in sight anywhere? Probably
2 more directly relevant is: How many of these multiple witnesses attempting to recall their false
3 lines written by Gans for a state case, are going to actually come forward and testify falsely as
4 ordered and thereby risk federal imprisonment when they bungle-up their story and inconsistently
5 and accidentally tell the truth about these things? Well know pretty soon.
6 Additionally, closer scrutiny of Kishpaughs 2016 SOL state trial testimony transcript will be
7 illuminating. Gans opening statement and Kishpaughs opening direct referred specifically to
8 seeing Remington speaking to John Mathson on a specific day in September 1998. A day when
9 Remington was not there, could not possibly have been there, was far away and was very busily
10 occupied doing other work.
11 Kishpaugh had a remarkable memory from 18 years before! What other days as you
12 remember so clearly from 1998?
13 However, when pressed by Remington and on his redirect, whichever the transcript indicates,
14 Kishpaugh decided to embellish all of that false testimony with his own casual, nervous laugh and
15 off-hand extemporaneous additions: Kishpaugh stupidly added and embellished that "he saw
16 Remington speaking to Mathson in 1998, on a dumpsite on Mathson's land that Remington never
17 saw or went to until at least five years later, not just once, but a couple of times".
18 That type of blatant and direct lie is just unacceptable makes Remington very angry, and he will
19 doggedly pursue those perjurious statements, and ultimately prove those are false statements, and
20 will keep working on that until he succeeds. Perjury by defendants is not okay here and will not be
21 tolerated by this federal court.
22 Clearly Gans coached Kishpaugh to say that he saw Remington over on Mathsons land once,
23 but not "twice". Kishpaugh hates Remington on many levels, and just had to wiggle the knife in a
24 little deeper with his "couple of times". Unfortunately, even once was false, and it was also too
25 conveniently remembered so CLEARLY18-years earlier, when Gans was desperate, and Kishpaugh
26 also needed money very badly. So now we will spend an hour or so on that at the next jury trial
27 beginning in Voir Dire.
28

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1 Kishpaugh is just a dumb, loyal, drunken, drug-using, old country musician, that old
2 neighborhood nuisance noise was probably intended to be; and, he is also a loyal RICO soldier who
3 will say or do anything to protect his "drinking buddy" and socially BEST friends, the Mathsons.
4 They also appear to have some sort of a complex drug dealing, sales or distribution
5 connection, with a constant out of the area flow of visitors at the Kishpaughs all day and most of
6 many nights, especially during warmer weather. Both Kishpaughs are not unsurprisingly, believed
7 to be (very long time) unemployed with their house deeply lost in foreclosure. Very desperate for
8 substantial funds to pay their mortgage in summer 2016 it is not surprising that Kishpaugh jumped
9 at the chance of getting a few thousand dollars of bribery money from Gans to say whatever was
10 needed to support Mathson perjury, and did so.
11 How Kishpaugh will be coached next remains to be seen, as a witness who may have seen,
12 heard almost anything, then will swear to it can be quite valuable to unethical criminal attorney
13 advocates, such as Gans and his racketeering inner circle.
14 In Gans 2011 Special Interrogatory Number TWO, Gans disclosed Harold Hilfiker as being
15 prepared to testify that he saw a Remington speaking to Skillings in 1998, but when the time came
16 in August 2016 to swear to that court, Hilfiker refused and did not testify at all for Gans.
17 More important, is what was omitted in that 2011 interrogatory. Omitted because the facts
18 never existed in the script by Gans not yet been written. Gans suborning of perjury became
19 necessary when Remington discredited Skilling's testimony 100% in pretrial hearings with blatant,
20 clear, conclusive photos from 2003 of the entire scene, which Skillings had falsely described and
21 sworn to. Those 2003 photos would have ended Gans entire SOL defense in case, however that was
22 unacceptable for Gans as defeat for him, or in this case "justice for Remington" is not an option for
23 a criminal enterprise, so Gans had to write an entire new script in July 2016 for Costa, Kishpaugh
24 and John and Joy Mathson. Gans new script was a massive "obstruction of justice". See below for
25 how Gans script influenced other witnesses such as Gary Costa, Skillings, Pulley, etc.
26 Kishpaugh was just as positive in August 2016 about his sworn testimony described above as
27 Costa was. The truth about what Kishpaugh actually knew was accurately written in 2011 and
28 it was supposed to be, as sworn to by Gans and John Mathson:

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1 Jon Kishpaugh is aware of nuisances (by Remington) and both Kishpaughs have been
2 bothered by noise All of that was true and correct and also is irrelevant and immaterial to any
3 of these trials. THAT WAS ALL KISHPAUGH KNEW AND ALL HE KNEW ABOUT THESE
4 CASES. Everything else that Kishpaugh swore to was an artificial, false, perjured script written by
5 Gans. It was actionable perjury in state court, nothing more or less, but it will be imprisonable
6 perjury next time. Therefore, those little nervous Kishpaugh laughs should be fewer and farther
7 apart in San Francisco federal court.
8 In other words, recapitulating, Gans false script in August 2016 was very different, very
9 important, absolutely 100% false, and entirely material and very influential at the statute of
10 limitations trial. As quoted above, what Kishpaugh swore to in August 2016 was totally different
11 than what was true back in 2011 and still in 2017, and therefore everything sworn to in 2016 was
12 false, perjury and we will prove that next time. Remington never walked the fill even once, let
13 alone "a couple of times" with John Mathson in 1998 and will eventually prove that critical
14 conspiratorial perjury, which had conclusive detrimental results against Remington, at the next
15 trials.
16 Kishpaughs basic culpability and state and federal crimes are perjury before a state judge and
17 jury and we will get that easily repeated in federal court with a San Francisco jury in the next stage
18 here, subjecting him to substantial imprisonment. Gans, defendants and Kishpaugh will need to be
19 very consistent in all future trials and we expect to be able to prove perjury in the future. Said
20 perjury has potentially damaged Remington $500,000-1,000,000, including all cleanup costs,
21 expenses, general and special damages, plus defendants costs, BEFORE treble damages if any
22 are assessed.
23 Therefore, if Gans and defendants RICO racketeering enterprise consistently maintain their
24 perjuries in federal court or better yet in federal discovery, then many of Remington's above types
25 of damages could be tripled, according to proofs, WHEN the first major RICO defendant or
26 defendants spouse cracks here under the pressure, throws Gans under the bus and tells the truth
27 to save themselves and their husband, or other incriminated suspect.
28 E. Morgan Randall. Mr. Randall was a former, young disreputable Westgate neighbor who
rented a small house directly across the street from Remington for several years around 1990. His
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1 limited dealings with Remington while Remington was actually at the site involved him begging for
2 permission to top 2-3 alder trees so he could open up the tiny part of an ocean view that was not
3 totally blocked by Remington's major 50-foot tall house structure. For several years Remington
4 refused to cut down any trees for someone on a month-to-month or year-long lease, however
5 Randall was a persistent, outgoing con-man type and eventually Remington grudgingly agreed
6 that he could top three trees.
7 Since Remington was never on his property during daylight, Randall got the key to
8 Remington's locked gate and eventually came in on his own and proceeded to cut down about a
9 dozen alders at ground level, because inferentially the first three did not do the job Randall had
10 visualized. So not only did Randall remove and kill four times the amount of trees authorized but he
11 also stole the firewood that Remington wanted and even dumped some of his personal garbage
12 down several small ravines, while he was there and then covered that debris with large piles of alder
13 branches, which took several years to deteriorate and reveal the mess. Remington never objected to
14 the Sheriff about Randall because at the time Remington thought Randall owned the house and was
15 there for the long run, as a neighbor so Remington acquiesced to his unreasonable requests.
16 However, when he moved a year or two later, Remington was surprised to learn that Randall
17 was not even the property owner and had just been renting month-to-month for a year or two, all a
18 long.
19 Now, according to Gans disjointed, abusive, extortive and evasive pretrial commentary, it
20 appears that Gans has coached Randall to offer some sort of false testimony about the
21 aforementioned events and perhaps also to claim that he sold perforated pipes to defendants, when
22 the actual evidence in the ground on that subject shows that said pipes are solid.
23 Randall may have sold perforated pipes to defendants at his hardware store, however that is
24 totally irrelevant and does not make the pipes in question perforated when the lying photographs,
25 four-foot ends cut off from said pipes and witnesses eyes themselves prove that the pipes are solid
26 and not perforated. Chances here are excellent that Randall looked for 1998 sales of 6-inch
27 perforated pipe, but probably did not check or verify sales of solid 6-inch pipe, which obviously
28 someone sold to defendants whether it was Pierson's, Hensells or Trinity supply, we don't know
yet. The significance of that issue has been explained elsewhere, and is somewhat irrelevant here.
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1 Today, Randall is a significant part of Gans corrupt RICO racketeering enterprise, and he is
2 expected to offer false testimony on any subject were Gans needs sworn disreputable testimony. He
3 is known to be a paid whore, apparently willing to swear to practically anything if the money is
4 right. Here, the money is always right since the RICO enterprise always has unlimited funding.
5 During discovery we will investigate whether Lawrence uses some of those unlimited funds
6 to pay herself some exorbitant amounts.
7 In a federal trial, Randall's relevance is that the criminal, unapproved trees, which he removed
8 from Remingtons steep southern slopes, were required for stabilizing that bank. Randall's total
9 removal and killing of said trees and their root systems on that very steep unstable slope, plus
10 removing the surrounding lower vegetation in those areas which also provided additional banks
11 stability, resulted thereafter in a massive 2013 slide of nearly 2000 yd which dropped 6 to 8 feet
12 vertically along a 120-foot break. Said large slide also moved 10 to 20 feet laterally down the
13 mountain towards Ridgewood Drive and Remington Creek, taking hundreds of mature trees and
14 bushes along with it. Damages from that slide were considerable, the future risks still remain of
15 much greater damages and dollar figures. Actual mitigation and repair costs are calculated and
16 estimated elsewhere in this complaint.
17 Morgan Randall is responsible for that latent damage occurring several years after his wanton
18 Alder removal and placement of garbage in two small ravines.
19 As part of Gans RICO extortion enterprise, Randall is known to have been thoroughly
20 "prepped and coached" with false scientific innuendos which in effect accuse Remington of
21 contaminating his own property, which ridiculous accusation and continues with the impossibility
22 that said contamination then spread 200 yards further downhill under a Creek and then up the next
23 mountain. All of that is ludicrous and impossible, but Gans scripts for his corrupt witnesses just
24 need to pass unsophisticated juror scrutiny, and not scientific panels, and hence they are specifically
25 intended for an impatient and unscientific juror mentality, and Gans tricks, devices and fraudulent
26 deceptions are perfectly designed to deceive the unsophisticated. Thus, a nice, personable extrovert
27 in Gans hands becomes a corrupt instrument of his crime RICO syndicate.
28 Randall appears to be just a RICO soldier at this time and not one of the dozen or more
major racketeering leaders involved in the enterprises various specialties such as, without
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1 limitation, the drug trade, illegal polling and excavations, violent vandalisms, money laundering
2 and the more serious pseudo-scientific cover-ups of all of the toxic and dangerous evils in
3 defendants dumps. However, until he is deposed we will not know whether he profited from
4 defendants money-laundering and extortion crimes, etc. against Remington. Also the exact degree
5 of his participation in or illicit profits derived from defendant's original 1998 hauling dumping and
6 concealment crimes is presently unknown. Similarly, whether he has been bribed now or just paid 3
7 to 5 times his ordinary store hourly rate of pay is presently undiscovered.
8 Randall presently works for a local building supply company that was in competition with
9 Eureka Building Supply, A subsidiary of the Burl Tree in the 1980s and 1990s, and destroying
10 Remington, the Burl Tree and there serious Broadway competitor Eureka Building Supply is clearly
11 one of Randalls motives mostly then, and still.
12 On the other hand, Randall got lucky in 2016 and was never called to deliver his perjured State
13 testimony and therefore does not appear to have YET committed any new federal predicate crimes
14 in the last four years, but if and when he testifies in these pollution cases, whether it is the state or
15 federal trial first, he is definitely expected to commit perjury at that time, subjecting himself to all
16 of the penalties cited in all of these federal statutes.
17 When the criminal investigation begins here, Randalls somewhat marginal role to date, due
18 to the the Luck of the Draw so far, makes him a likely candidate to turn-in Gans and John
19 Mathson to the FBI, district attorney and related ethical investigators. Oddly, here, turning-in or
20 ratting-on Gans and his RICO enterprise merely means telling the truth to investigators or
21 Remington during discovery, nothing more or less. Ordinarily that would seem to be pretty simple
22 for a somewhat unimportant RICO member, but here Gans will no doubt make that very
23 complicated, and eventually subject Randall to possible federal imprisonment charges.
24 It now seems quite probable that he will opportunistically figure-out a way to save and/or
25 exonerate himself in some sort of betrayal of Gans' extortion racket, since Randall has a good job
26 and a family and may not want to risk going to prison over executing Gans corrupt perjury requests.
27 Additionally, Randall is presently believed to not yet be as deeply involved with Gans
28 Enterprise, as any of the other named defendants, or the unnamed Potential defendants, which are
being seriously considered for addition. There are several reasons for that, including that he
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1 fortunately for himself left Mathsons drug and drinking-buddy gang along Westgate Drive many
2 years ago, and now lives about 20 miles away were he rarely sees any of the defendants.
3 So, in essence, Randall got very lucky in the draw and that the DR080669 trial, for which
4 he was carefully coached to testify, was settled in May 2016, and then the next TWO contamination
5 trials where Randall was scheduled to present his totally, completely closely coached and mostly
6 perjured testimony were indefinitely postponed, and they remain so. Why Randall would want to
7 now get heavily involved in this Civil RICO case (with criminal overtones) to help self-serving
8 obviously criminal racketeering leaders such as Gans and Mathson, etc., is unclear and will be
9 determined in part on whether Randall will charismaticly follow Gans, as though the latter were a
10 Pied Piper, leading everyone in his spirit tutorial family all straight to prison or hell.
11 F. Joy Mathson. Mrs. John Mathson is the angry, older wife of the main defendant and
12 protagonist here, John Mathson, who has been characterized above as Gans puppet or marionette.
13 Ms. Mathson is a trusted inner-circle charter member of Gans RICO extortion racketeering
14 enterprise, and in many ways is its de facto Queen, although she remains just a minor power
15 figure compared to Linda Lawrence of Allied insurance. Her deposition was conducted in 2010 by
16 attorney Harvey Roberts and she did make an attempt to honestly tell what she knew about this
17 criminal situation before it had become a RICO enterprise, and her deposition is overall highly
18 helpful to Remington when it is eventually presented in detail at a trial.
19 It was clear in August 2016 from Joy Mathsons arms full of notes and general demeanor that
20 she was well-coached by Gans, primed, nervously confidant and ready to join-in as a star-rebuttal
21 witness. Gans already had four colluding witnesses on the major issue of the SOL trial, and she was
22 obviously intended to be a fifth corroborating witness, to help win over the old ladies on the jury.
23 However, she seemed too well-prepared and eager to be called as a witness so she wasnt.
24 She will absolutely get her chance next time, to see if shes smart enough to sift-through,
25 dodge, weave, corroborate and navigate through the Gans RICO false mine field of lies which her
26 husband John, under Gans' close tutelage swore to in August 2016. Shes expected to have plenty of
27 trouble next time when she does testify as to what she guesses, thinks and tries to recall from what
28 John Mathson said or meant (as severely modified by Gans rewriting of history) in the years of
1998 to 2004 through 2008, Etc. All those years are highly confused by both Mathsons and a clear
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1 timeline when presented and substantiated by actual evidence, and the many sworn statements over
2 the years which were essentially reversed in 2016, will easily trip-up both Mathsons and prove
3 they are BOTH liars. Gans will prepare them endlessly, but as we discovered in August 2016,
4 both Mathsons really want to tell the truth and when they get confused or tired, thats just exactly
5 what they will do. That truth problem is a case killer for Gans and this enterprise. Fortunately,
6 the truth will WIN Remingtons case and defeat the Gans/Mathson defendants, probably in an ugly
7 way in San Francisco.
8 Its obviously hard to memorize false information at age 65-70, so well see what her mental
9 competency is in a couple of years, well into her 70s. Remington is nearly 75 already, and has
10 therefore already begun occasionally experiencing that problem, hence he decided partly by
11 necessity, to just fully tell the truth as that is easier to remember with an older or fuzzier memory
12 than the lying narrative, which Gans has written for too many, and essentially ALL, of his
13 witnesses.
14 Joy Mathson got lucky and missed her chance to become a present full-member of this
15 RICO obstruction of justice group because she has said nothing and done nothing here since
16 2012, worthy of mention. She plays a good aggrieved, bravely persevering victim of Remingtons
17 oppression in the court room, and she should get plenty of additional practice, while waiting her
18 turn at the next trial to violate some major and serious federal predicate acts.
19 Therefore, today, Joy Mathson is now merely a backup member of the RICO enterprise, and is
20 not named yet as a full member. So far in this case, she is merely a cheerleader since 2012, but as a
21 joint landowner of the Mathsons portion of the dump, she is involved in all causes of action on the
22 cover page of this complaint, because of her involvement and her direct implication in the
23 contamination acts from the 2008 lawsuits going back prior to 2012. Therefore, her situation is
24 somewhat complicated and ambiguous in that she is implicated in the real estate and contamination
25 related damages cost to Remington over the last three years in his environmental successive
26 action here, but shes not currently a defendant in the RICO cause of action involving the period of
27 2012-2016 and counting.
28 The primary reason for that is that she has not yet committed any known RICO felonies
herself in the 2012-16. However she is a major enterprise planner, trial and felony cheerleader
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1 and therefore a serious criminal accessory to John Mathsons over 100 major vandalisms, burglaries
2 and other related criminal acts complained of herein.
3 Because she is and intimate, Inner Circle Member of the Gans defense team since 2007, she is
4 very knowledgeable about everything that goes on here and especially about Gans, Skillings and
5 John Mathsons RICO crimes. Shes a very close and continuous daily confidante of John Mathson,
6 who was and generally has been the central, full-time 24-7 RICO soldier here, responsible for at
7 least several hundred crimes, which she is very knowledgeable about. Joy Mathson is complicit in
8 and an accessory to all conspiratorial and criminal acts that this court finds that both Gans and John
9 Mathson were guilty of.
10 Therefore, when John Mathson, Gans, Olson, Skillings and the others are sentenced to prison
11 and she sees that she could share in some of that, it is expected that she will likely decide to
12 (tearfully tell the truth) for the first known time since 2010.
13 Joy Mathson knows as much or more about all of this than Remington himself does certainly,
14 and hopefully when the criminal authorities first interview her she will decide that abandoning
15 Gans and her husband John at this early federal stage, before we generate enough additional
16 criminal predicate acts, for her and likely many of them, to do 10-20 in jail, would be her most
17 prudent course. Obviously thats not for Remington to judge are to say at this point, but at some
18 point her enmity towards Remington may be pushed aside, and she may decide to opt for justice, in
19 order mostly just to save herself and attempt to live out her remaining years on Westgate Drive.
20 As discussed elsewhere, actual JUSTICE here starts with the reasonable clean up that
21 should have been done here 10 or 20 years ago in this case, and then defendants need to do what
22 else is necessary to resolve the other damage issues that will end this dispute, so we all can resume
23 our lives, after substantially losing about 10 years here. Why should Joy Mathson join Gans and
24 some of the others in prison, just because Gans was too inept to defend these lawsuits ethically and
25 legitimately? Alternative, why should she not?
26 HOWEVER, all defendants, especially Joy Mathson should be clear about one thing: after the
27 filing of this federal action, within the first month when Remington initiates written Special
28 Interrogatories to all important parties here, the first questions he is going to ask them under oath
will involve the 2016 State SOL trial perjuries, and who is willing to reaffirm their oral perjury and
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1 written documents in the federal case, which now would be subject to federal perjury, witness
2 tampering and obstruction of justice federal felony imprisonment penalties, as described herein.
3 Also as described herein, we expect to prove those allegations and make them stick on
4 whoever is foolish enough to repeat Gans RICO conspiracies state frauds, lies and material
5 deceptions in the federal forum.
6 It is not Remingtons purpose or place to threaten or advise anyone who may read this
7 document, however presumably anyone receiving and answering a Federal Special
8 Interrogatory, document request or US attorneys subpoena, will have obtained excellent legal
9 advice and thereafter will obviously attempt to tell the truth and not get hopelessly and inextricably
10 implicated deeper into the endless web of Gans civil and/or criminal RICO conspiracy.
11 H. Gary Costa.
12 Costa was one of the original Gang of Four perjuring SOL trial witnesses in August 2016.
13 Gans wrote Costas script about seeing Remington on Mathsons site on his birthday in 1998 (if you
14 can believe that!) while buying a plant for his wife, and then Gans imaginatively added that Costa
15 knew Remington well from buying good burls at the Burl Tree 20 or 30 years before that, while
16 he was a little boy, purportedly with his father. Naturally, Remington has zero recollection of any of
17 that, nor does he remember specific interactions with more than a tiny fraction of customers from
18 1998, or in this case supposedly the 1970s!
19 Costas entire story was highly contrived, ridiculous, too convenient and false, however
20 Remington was unable to refute or destroy Costa, so the jury apparently believed him, and accepted
21 his testimony as true. The truth is however, that Remington was never on Mathsons land in 1998
22 until after 2004 when the fill was entirely buried and concealed underbrush as portrayed in the
23 photos provided herein.
24 Costa was a fellow long time pulp mill union member with John Mathson who would probably
25 gladly give his life for John, so lying per Gans script, to say that he definitely saw Remington
26 somewhere talking to Madison on a very known an exact date only 18 years ago, was no leap at all
27 for Costa. Costa seem like an honest old guy which made him harder to refute, but will do it better
28 at the next trial. There, the statute of limitations and the actual substance of what the five perjurers
had been coached to say and to cooperate with and corroborate each other is not as important. But
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1 federally the fact of trial perjury meticulously coached by an unethical California licensed attorney,
2 with the help blessings and knowledge of two or three other attorneys, will be important. We can
3 prove all that now and we will.
4 On page 4:15-17 of Gans and Mathsons above-cited, Special Interrogatory Number TWO,
5 Gans wrote: "Gary Costa has been on the Mathsons property was present in 1998 Phil was
6 placed, and knows the dates and the general nuisance conditions of Mr. Remington's property".
7 That was all accurate then when written, is still accurate, and that was all that cost a new from 1998
8 that was true.
9 However, being the loyal fellow pulp mill union worker with John Mathson described, for
10 about 30 years, it was easy for Gans to augment that script to get Costa to lie, and to add the
11 obviously phony story about visiting a nursery on his birthday on September 15, 1998, 18 years
12 earlier. On that date, which Costa very (and much TOO) conveniently remembered, he just
13 happened to see Remington there, and further, just as conveniently, Costa also just happened to
14 absolutely recognize Remington, and claims that he knew him from some kind of meeting earlier,
15 although Remington had never seen him before in his life, in his memory. Costa did not even speak
16 to Remington on September 15, 1998 but still clearly recalls seeing him there for two or three
17 minutes, all of which makes no sense, is not credible, nor is any reason given for why Remington
18 made such a profound influence on Costa. Remington is a serious gardener who has purchased
19 about $200,000 of plants. He has made literally hundreds of visits to many nurseries over the years,
20 and could not cite the exact day of the week or month with regards to any of them, nor could he
21 even guess the year within 2 to 5 years on any single nursery visit.
22 WHY did that fleeting glimpse, that Costa claims that he made towards Remington, which was
23 so profound that he recalls it very clearly all these years later, make such an indelible impression
24 and memory? Well, because that's the way Gans needed it and wrote it.
25 The truth is that this Gans script written for Gary Costa was just a bunch of bull from the
26 beginning. Worse than that it was false in being deliberate intentional perjury and they and "we" all
27 know that. If Costa had seen Remington walking the fill in 1998 than that would've been
28 profoundly important back in 2011 and probably would've ended the case at that time if it was true.
That omission from Special Interrogatory Number Two is crucial and ultimately will conclusively
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1 prove that it was false. Remington now has an elaborate cross-examination by omission strategy
2 which will eventually reveal the truth about this and the whole complex of related suborned perjury
3 at the August 2016 trial. Judge Reinholtsen heard all this and you would've thought he would've
4 seen through it however but he didn't. He was biased and prejudiced in favor of Gans but the next
5 trial will focus on this perjury and proven as such.
6 Gans is clearly the first and main target here, but once he goes down many of the others
7 named in this RICO statement should "swing" beside him. The federal system in San Francisco has
8 plenty of gallows available, enough for all. That's the beauty of the RICO act, we can get the
9 Godfather, his advisors, all his confidants and also all his soldiers and lower-level emissaries, that
10 can be conclusively tied to him, through the numerous specific predicate acts committed here by
11 many of them.
12 Here, "the others" includes perhaps a dozen individuals including some of the groups of both
13 the presently named defendants and "near defendants" at this time, which lists today goes all the
14 way down as far as Mickie Kishpaugh, today his 29th on these lists and there still are many DOE
15 defendants to yet identify.
16 We know for a fact that Gans has considerably more perjury lined-up with many of his state
17 witnesses, including people like Randall, Harold Hilfiker and Gary Evans, etc. Exactly how many
18 RICO members will eventually be identified is unknown today, because we now know more will be
19 added and probably some others will be dropped during discovery over the next few years.
20 With a likely state contamination trial progressing in parallel to this RICO case, it will make
21 trying any state case perjury (where massive perjury is committed every day by Gans witnesses)
22 from Humboldt County easier to prosecute in the federal RICO action in San Francisco.
23 H. Melissa Martel, was the Director of the County of Humboldt Department of
24 Environmental Health from 2008 to at least early 2016 but what her exact status and bureaucratic
25 position is today is unknown due to the detrimental reorganization of their website20. During the
26
For many years, especially the last 10, their website listed all personnel, titles and phone numbers. Now,
20
27 however all of that has been deleted and without calling them on the phone it appears to be impossible to
determine who works there, what their titles are, what their individual responsibilities are and who they
28 work for. Even when Remington did call them on the phone, everyone is very secretive and circumspect
about anything that they do, or who works where and does what. Why they have done that is unknown,
however it is now difficult or impossible to determine individual culpability for any problem, nor can the
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1 eight years cited above however Martel made many major decisions, which potentially could have
2 greatly affected these cases. Unfortunately, most of her decisions were to do nothing and essentially
3 to condone Mathsons, RAOs, Brissos and now the RICO enterprises dump and criminal behavior
4 in establishing it. She did most of that in collusion with Brisso, Gans and their special envoy Esko,
5 as described below.
6 As alluded to in footnote #20, above and below, after a 2015 investigation by Remington, Larry
7 Lancaster, Ms. Hawkins and Amanda Ruddy are now named here as possible Martel Confederates
8 who are knowledgeable about her Esko connections and the improper and coercive Brisso-Gans
9 influences within that department. Those named above, are important material witnesses in these
10 cases, who are Not likely actual RICO enterprise members, pending further discovery in their
11 department, which is already in progress.
12 Martel has a rather complex history in these cases, so to simplify that here, it was her unusual
13 decision to appoint the special envoy and non-employee Peter Esko as a consultant in this case
14 which is of most interest here. Esko was apparently brought in to these cases solely to suddenly and
15 unexpectedly exonerate Brisso's client the Mathsons of all environmental charges from the County
16 or the Waterboard, when it was totally obvious to everyone that they had violated every known
17 environmental law in 1998, which violations continued into the present.
18 It would be difficult to under-state the oddness and inconsistency of involving Esko in these
19 matters or to understand or explain the inconsistencies of his decisions here, strangely approved by
20 Melissa Martel.
21 For example, Richard Miller is well-known to Remington and this entire Eureka area and he
22 was fined $100,000 by the Health Department under Martel for doing much less than what Mathson
23 and RAO did. The only difference discernible to Remington is that Brisso was representing the
24 latter enterprise defendants and had a close and inferentially unethical association with Martel
25 through LAFCo and probably other associations, such as the county counsel's office. Improper
26 influence and power? All of that seems to be present here, however in fairness, more detailed
27 public track any individual employee, hierarchy or do any sort of litigation investigation for a motion or
cause of action. Over the years, Carolyn Hawkins, Larry Lancaster, Maje Hoyos and Melissa Martel have
28 all played important parts in these litigations but now it is difficult to get any records about what they did
or said without reviewing 2-8 year-old notes, and getting any of their work product or conclusions from
past investigations has always been difficult, but now appears to require a subpoena or court order .
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1 discovery of all types is now required here to determine exact facts.
2 Melissa Martel has communicated by letter with Remington, around 2010-12 and has
3 eventually sent-out Maje Hoyos on several occasions, to investigate these dumpsites, but always
4 MANY months too late when County assistance had already clearly become essentially useless.
5 Remington has virtually begged her several times to send out investigators, take tests or do
6 something useful to resolve these contamination problems on two sites, yet she has always almost
7 100% ignored Remington and his entreaties. To Remington and all of his environmental experts, it
8 has always been a matter of great consternation as to why Ms. Martell did not take Remingtons
9 contamination seriously, and the strong inference has always been that she was under incredible
10 pressure from Brisso in particular, who was undoubtably sparked by Gans. During discovery here
11 Remington will put together the odd and apparently corrupt timeline of letters, pleadings by
12 Remington to take various timely actions which might have been useful for trials, all of which need
13 to be studied in terms of the odd background, and screamingly loud corrupt implications of how
14 the county completely ignored Remington and his experts entreaties 100%, and for many months,
15 until it apparently appeared to Brisso (and Martel and her staff) that tests or action by the county
16 would now be too late to assist Remington at any trial. In other words, once Brisso and Martel
17 believed that testing and reports by their County investigators such as Maje Hoyos, were much too
18 late, and could not help Remington at all, then they were all over Remingtons property with
19 substantive tests and investigations in December 2011. Happily, those extremely late tests which
20 were intentionally scheduled by the above so as to be totally useless in DR080669 and DR080678,
21 now have accidentally become extremely relevant on all additional cases which continue.
22 Reiterating in different words, several times the only thing that was needed was Martels
23 authorization or signature, however she has always found numerous unknown, but above inferred
24 reasons to procrastinate, obfuscate, and do nothing for years at a time. BUT, ultimately she
25 approved decisive actions in November-December 2011, however that was only after she had to
26 know, and obviously had been told by Brisso or Gans that not only was there no contamination
27 here but that taking tests 6-12 months after discovery had closed would not help Remington at all in
28 his contamination trials in the two above cases, and Brisso also made it clear that not having those
tests would lead to Remingtons resounding defeat. In that instance, the RICO enterprise would
237
1 reach all of its objectives, and said enterprise was just being conceived and formed in its earliest
2 2012 manifestations, which was at approximately the time of, and somewhat after, the Esko and
3 Hoyos reports had been created and then thoroughly understood and put in proper perspective.
4 That is, what all named above appeared to want, was for the county to do nothing and for
5 Remington to disappear and leave all contamination alone on both sites. That was the opposite of
6 what the Hazardous Materials Unit should have done, and was the exact opposite of what all her
7 site investigators assured Remington about the actions that the county would definitely be taking.
8 Those actions were absolutely quoted and defined by all County investigators from 2008-11, which
9 were that : sooner or later the county will order the cleanup of both properties, that meant that
10 the county would be ordering cleanup actions of all contaminating materials by Gans, RAO and
11 Mathson, pursuant to Remingtons requests. However, Brisso killed all of those young enthusiastic
12 investigators promises and commitments when he got very heavily involved in these cases in 2009.
13 Why Martel was so overtly prejudiced against Remington, when all of her site investigators
14 represented the opposite position; and, exactly WHY she was so unduly biasedIn favor of Gans,
15 Brisso and Mathson remains to be discovered. Why would she bend County policy and go against
16 their own investigators so directly in order to benefit the major contaminators RAO, Mathson and
17 by that time the Gans- Brisso RICO enterprise? What was the quid pro quo? What benefit did she
18 derive from all of this? Those are some of the inquiries we will be making in this case and it would
19 appear that Martel has a lot of explaining to do and we will need to subpoena her personal
20 documents to see if some kind of financial benefit was involved here.
21 For some factually unknown reason, however, (although we have our present unflattering
22 and possible examples of and interferences of possible gross irregularities or the corruption alleged
23 above), Ms. Martel does not take these toxic contamination cases very seriously, especially the
24 contamination on Remingtons land. There is asbestos and many kinds of highly toxic wastes both
25 airborne and waterborne, plus gas station remediation drums, etc. buried in Mathsons draw, yet the
26 county just can't get motivated about it for some reason.
27 In 2008-10, Maje Hoyos and Mark Johnson both PROMISED that "sooner or later
28 both properties will get cleaned up", but the top Humboldt County Health Department authorities,
from Martel on down, have since then "slow-walked" these cases, and then suspended them
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1 entirely. Now the California Waterboard supposedly has the contamination files from the county,
2 but again inferentially the power of Brisso has far-reaching effect to obstruct investigations here.
3 Remington totally and completely relied upon Hoyos and Johnsons promises above, and
4 thereafter planned his entire litigation strategy for at least six years on that reliance, only to have it
5 proven, or at this point strongly inferred, that Martel has been improperly influenced, intimidated
6 or bribed, and is in any case somehow controlled by or otherwise involved in a quid pro quo with
7 Brisso, Gans, Plotz, Mathson, and/or others at a minimum.
8 For many years, Remington has inferred and learned from several indirect and
9 knowledgeable sources that Brisso, the county attorneys office and related forces above, have
10 inexplicably become involved in all minor aspects of the Remington-Mathson litigations. They
11 have not assisted or furthered said investigations, but have for years slowed-them-down, blocked
12 them, or substantially and inexplicably impeded their progress in any case.
13 For example,The Esko letter can only be concluded as proving that the county has totally
14 sided with Mathson and the Mitchell firm in these litigations and is now assisting in the major
15 pervasive cover-up of all of the problems enumerated in these documents, and conclusively have
16 determined that all of the massive contamination which still exists on both sites today can continue
17 to exist, exactly where it is and it can continue to infect and pollute the environment, as complained
18 of herein.
19 Remington believes that Brisso has improperly influenced Martell and her department to
20 acquiesce to Mathsons contaminated dump and essentially to not do anything to either clean it up
21 punish defendants for establishing it there in the first place. Probably the district attorney will have
22 to get involved here to investigate and understand whether this RICO conspiracy has reached deep
23 into the Health Department and affected these cases or whether there are some other innocent
24 explanations for what's going on here, which are unfathomable and incomprehensible to
25 Remington, as will be determined shortly by discovery.
26 Ms. Martell should be deposed or investigated by the County DA, and by the wider federal
27 authorities when they get involved, because as alluded to above, getting any useful investigations
28 from a Eureka department reputedly and/or inferentially controlled by Gans, Brisso and the RICO
enterprise appears somewhat unlikely, although we will try and see what happens factually and
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1 evidentially. Maybe Remington is out-of-line and the sites are just not contaminated enough" to
2 warrant county or state action. Remingtons experts think that there is serious contamination here,
3 now gravely damaging and posing an imminent threat to the environment and that all contaminants
4 should be removed from both properties, and that the cover-ups now ongoing, already arise to
5 criminality here.
6 Meanwhile, at present it cannot yet be proven that Martel has "done any wrongdoing" in
7 these matters, however she inferentially does appear to be involved in this RICO enterprise
8 although possibly on its fringes, as inferred and alluded to above. Brisso is such a powerful figure
9 here that, it cannot be overstated. It is very likely that his influence, power in the fear and respect
10 that he inspires, has reached DEEP into the County Counsel's office to obstruct Remington's
11 relationship with his witness Ms. Hoyos. What young attorney just starting-out with the County is
12 going to do anything to oppose Brisso? We will have our own preliminary investigatory answer to
13 that quite soon.
14 On the other hand, Ms. Hoyos bosses Martell and/or Larry Lancaster could either be directly
15 involved themselves or just influenced by Brisso and/or his powerful attorney friends, associates
16 and/or agents. Obviously, there are many questions remaining here which will require extensive
17 discovery. Equally obvious is that none of these agencies ,and potential enterprise members are
18 going to voluntarily provide any information about anything, so a long complicated expensive
19 discovery process can be expected.
20 Melissa Martel is effectively insulated by 4-5 layers of subordinates, so "reaching her" for
21 proofs of any wrongdoing is likely beyond Remington's power and likely will take confessions
22 from only one of the following group: Gans, Brisso, Plotz, Mark Johnson, Maje Hoyos, Amanda
23 Ruddy, Carolyn Hawkins, Julie McBride, Peter Esko or others who may be knowledgeable of the
24 situation.
25 One or two of that group with a common story of wrongdoing could easily implicate Melissa
26 Martel, or any others involved or maybe they'll exonerate her, as Remington has no present absolute
27 proofs of her wrongdoing per se. What we have now is just an obvious strange and determined lack
28 of desire, TOTAL lack of diligence or any motivation to go zealously after a Gans/Brisso client and
RICO enterprise WHO obviously collectively (in and around 1990-2003) were much more common
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1 criminals and felons, is thoroughly described herein, than Richard Miller ever was. Here, the
2 WHO potentially obviously includes the Mathsons, RAO, Olson, Skillings and their associates,
3 the original 1998 era criminals that Gans RICO enterprise now protects, while simultaneously
4 attempting to destroy Remington and his business financially.
If Melissa Martel was eventually convicted of some kind of complicity in the possible
5
predicate acts alluded to herein, then arguably she has alone from her lethargy and inactions caused
6
Remington more than $100,000 in direct damages, plus several times that dollar amount in lost
7
time, over 8-10 years and counting. Ms. Martell could have ended all this in summer 2011, but
8
chose not to, as she has slow-walked, obstructed, or possibly worse, the Remington investigations
9 and waited, until it was far too late to help Remington at any trial, before she would allow
10 Maje Hoyos to conduct her December 2011 investigations. Inferentially, Martel was fully apprised
11 of the state trial schedules, and impeded all investigations before any trial and then scheduled
12 them for long after all anticipated trial dates, to such a time when Brisso assumed that the cases
13 would be 100% over.
14 Those December 2011 investigations were needed for two trials set many months earlier in
2011, but were postponed. However as a result, Judge Reinholtsen STILL barred those tests from
15
any use whatsoever in those first two 2008 filed cases, which has also greatly prejudiced
16
Remington. Whether Brisso successfully plotted the prejudicial collusion between Ms. Martel and
17
Judge Reinholtsen is a possibility, but is presently unprovably speculative until we develop further
18
factual details about it over the next couple years in discovery as explained.
19 In the future, Ms. Martels culpability, possible corruption or innocence will likely depend
20 upon the Esko report details which are enumerated below in the next section. Why did Martel and
21 Esko not get two sides of the issue from our preeminent, nationally respected contamination expert
22 Aveggio, when we offered his assistance?
23 Why wasnt the status of Mathsons dump considered to be an adversarial issue where two
24 sides were reasonably and fairly consulted, rather than what actually did occur which was just a
direct, obvious and deliberate, planned exoneration of Mathsons massive contaminated hazardous
25
waste dump?
26
This situation was analogous to when President Clinton improperly and very controversially
27
met for 40-minutes on the tarmac with Loretta Lynch in Arizona in summer 2016. Simply put, it
28
stinks. Similarly, ditto as to the obvious corrupt Trump to Russian connections during the campaign

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and since then. The appearances there and here are of a bribe, blackmail (as to Trump) or similar
1
quid pro quo which now will need to be expensively explored in depositions with attorneys trying
2
to block those depositions because they potentially could bring criminal culpability to Esko, Martel,
3
Brisso and many others potentially involved then or in the subsequent cover-up today, in 2017-18.
4
I. Peter Esko, the very special envoy from the Humboldt County Environmental Health
5 agency. The Humboldt County Hazardous Materials Unit has more than a dozen investigators and
6
scientists that could have studied the scientific data from these contaminated dumpsites to make some
7
kind of a determination, yet they brought in Esko the extra-legal, non-employee who inferentially is a
8
corrupt, malleable low-integrity bureaucrat, who in any event is willing to do or say or write
9
anything, clearly.
10
Mathson and RAO created arguably the largest residential hazardous waste dumping County
11
history and there had been at least three previous major investigations here prior to Eskos cursory
12
review of a biased, one-sided Blue Rock document, and purported report. Of those prior
13
investigations, Paul Dalkas apparently corrupt observations of the original dumping sites
14
contemporaneously with when the contaminated debris was actually dumped there, inferentially
15
involved bribery by RAO Construction. Whereas Maje Hoyos and Mark Johnson, as above both
16
assumed and then told Remington that all contaminants would eventually have to be removed from
17
both dumpsites. The most highly respected environmental expert in any of these cases ever was
18
John Aveggio of SHN. Yet none of those latter three were consulted by Esko when he made the
19
strange, important decision suddenly to exonerate the Mathsons/RAO dump for all time, based on
20
clearly spurious law and reasoning.
21
WHO asked this question to the county in the first place, about whether Mathson and RAO
22
could just leave their hazardous materials from 1998 there forever, or not? Remington had not
23
asked nor was he consulted when the question was asked. Nor did Esko and Martel ever want to get
24
an objective report, which considered both sides because our expert Aveggio was never consulted
25
and we tried to get his input into the case. Obviously Gans and Brisso presented that hypothetical
26
question to Melissa Martel themselves, so that they would be guaranteed to get the answer that they
27
wanted, expected and demanded for their guilty clients John and Joy Mathson.
28

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1 This entire issue is somewhat complex. Simply put, defendants wanted and needed a full
2 exoneration to use against Remington and they could not get it from any knowledgeable and
3 independent expert that had investigated the toxic waste dumps. Instead, they brought in a bribable,
4 malleable ex-County employee who apparently for the right price or for a weeks County salary
5 would evaluate this dump and exonerate anything, and he did so.
6 Esko did not consult our side or Aveggios work at all and used 100% incompetent, now
7 fully refuted Blue Rock data and boring logs to determine that Mathsons hazardous waste dump
8 was just fine in the middle of our redwood forests and was not a threat to the environment or to
9 anything else.
10 Because data from only defendants side was considered, Gans, Brisso and Martel expected
11 and obviously sought, a one-sided decision favoring defendants and they got it.
12 So far, Esko has proven he is corrupt, and he is also an enigmatic, ambivalent figure, that no
13 one in the Hazmat Department of Health understands or relies upon21.
14 At any future contamination trials Gans and Plotz claimed that they intended to use Esko to
15 disingenuously argue:
16 1. The area of the contaminated debris on Mathsons portion of the overall dump is larger, worse
17 and hence supposedly a larger problem than the debris on Remington's land;
18 2. The dump on Remington's land came directly from Mathsons larger and supposedly worse
19 dump, when the actual factual truth is that defendants meticulously and admittedly sorted all of the
20 21
In fall 2015 Remington conducted an extensive inter-department survey of Peter Esko tried to
21 understand who we was and what he did here. That phone survey involved speaking to Amanda Ruddy,
Larry Lancaster, the receptionist at the Hazmat Unit, Maje Hoyos, Carolyn Hawkins and several others.
22 Contrary to what Plotz fraudulently stated and misrepresented to the court in his sworn motion documents,
Esko was not Mark Johnsons replacement was not even from that department, but was a fraudulent
23 investigator solely created and hired to exonerate Brissos clients the Mathsons and to further crush
Remingtons case in pursuit of the RICO enterprises objectives. Esko is no less than a fraudulent con-artist
24 who Gans and Brisso created in order to argue that if there is no contamination on Mathsons property
25 therefore despite your lying eyes, tests and experts, there also must be no contamination on Remingtons
property. Without going through the entire analysis, that is entirely false deceitful logic and ignores the
26 crucial fact that Skillings admittedly carefully sorted all of the hazardous wastes in 1998 placing the worst
hazardous 15-20,000 # of Asbestos and chrysotile onto Remingtons property and buried it, because
27 Mathson refused it on his own property. Additionally, Remington has been assured by knowledgeable
sources that Esko will never testify in these cases under penalty of perjury, because to do so will expose the
28 corrupt Martel to Brisso connection, plus his conclusion is illogical, unscientific and unsustainable against
expert analysis and scrutiny. Therefore, arguably the whole Esko fantasy created by Gans and Plotz is
another disguised extortion tactic to force Remington to surrender his land.
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1 worst hazardous materials and very specifically the 15-20,000 pounds of friable asbestos and pipes
2 onto Remingtons land, making it by far the most toxic and hazardous area despite being of smaller
3 volume than what remained on Mathsons land;
4 3. "The County as far as this decision is concerned consists of Esko and Martel only and
5 conspicuously not Johnson, Hoyos, Aveggio, Lancaster, Hawkins, Remington or any credible
6 independent expert. Said County executives have ruled now that Mathsons dump is benign, is a
7 lawful use (however Richard Miller got fined $100,000 for a similar lawful use), is not an
8 imminent threat to the environment or to air quality, or to Remington Creek and therefore does not
9 need to be removed in the public interest. To conclude that required knowingly one-sided,
10 fraudulent, incompetent testing and false out-of-time data, and probably conspiratorial collusion
11 among the involved County and RICO enterprise members;
12 4. Therefore, because Remington's dump came from the same source as Mathsons and because
13 Remington's dump is not as big, as "bad" or not as allegedly poisonous, Remington's dump must
14 also be benign, not require any removal, not be adversely affecting the environment, not being in
15 "imminent threat" to the environment, and therefore (again illogically as is this entire syllogism)
16 must therefore remain were defendants dumped it for all eternity;
17 5. To conclude all of that, Esko oddly did not visit either site or closely review or understand any
18 of the tests or evidence from Mathsons property; also, he did not see any of the tests from
19 Remington's land, did not understand that Skillings very carefully sorted-out all the worst toxins
20 in 1998 and placed them on Remington's land, and in essence just made-up his conclusions
21 completely. Had Esko been interested, he would have discovered that the worst toxins including
22 the lead, heavily concentrated hydrocarbons, all of the asbestos and chrysotile etc. were very
23 carefully sorted onto Remington's land and therefore Remington's land does need cleanup whereas
24 Mathsons is an open question and not involved in this lawsuit.
25 Discovery is expected to eventually prove that Esko was bribed, simply put, either by means
26 of an innocent County paycheck or perhaps directly with independent Brisso-Martel-Allied dollars
27 or other financial promises or inducements. Bribes, quid pro quos and similar corrupt or improper
28 influences cannot yet be proven or cooperated until substantial discovery among those named above

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1 has successfully been compelled. Esko's decision was biased, corrupt, had no objectivity or merit
2 and will be investigated by the district attorney shortly.
3 Meanwhile, Esko and Martel are not yet named as defendants, but clearly are present
4 members of the RICO enterprise which were improperly and corruptly influenced by Gans
5 and/or Brisso, and it would not be unexpected if one or the other, or BOTH of them are named
6 as RICO defendants in the FAC.
7 CONCLUSION: The more Remington analyzes this Esko fiction by a phantom ex-County
8 employee, improperly paid hired-gun, biased outside consultant, that does no actual work for the
9 the County and who may not even reside in California, the stranger this innovative new corrupt
10 Gans extortion device becomes!
11 Although Esko has not yet testified here and has not yet caused Remington substantial
12 financial damages, this is still yet again another direct and successful extortion attempt by Gans
13 because it did induce fear in Remington, because it all came from the purportedly neutral county,
14 and wasnt possible to fully refute after Judge Reinholtsen refused to allow Ms. Hoyos into the
15 case. Properly used in the hands of an unethical con-man attorney, backed up by credible, motivated
16 and believable testimony from Gans misrepresenting and supporting Blue Rock experts, Gans
17 might have won the jury over with one such witness, considering the fact that Aveggio is dead and
18 Remington would primarily be reading his testimony.
19 Monetary damages attributable to Esko, have already been caused here, however if he ever
20 testifies in collusion with the other enterprise members discussed above, damage done by that
21 enterprise member could be incalculable. Today, Remington has spent countless hours of worry,
22 writing counter-memoranda and declarations, plus spent extensive and costly time working with all
23 5-6 of his current and primary environmentally and real estate related experts to endeavor to
24 counteract Esko's fraudulent and deceitful projected testimony.
25 J. Liz Smith was a County of Humboldt Superior Court file room clerk who gave Remington
26 an especially hard and inconsistent "time" over how he clipped his filed documents together, at the
27 top. The details again are complex and largely omitted here, with 10-20 pages of related letters to
28 the Superior Court executives existing in the files. Simply put, Remington filed his documents
correctly as per the appropriate CRC regulations, and all Remington's documents were eventually
245
1 filed, and additionally he had no further problems for several months after complaining and making
2 a fuss about Liz Smith and also another similarly obnoxious and obstructing file clerk, Candy B,
3 who follows next.
4 Since no specific or absolute positive proof of felonious wrongdoing exists yet incriminating
5 Liz Smith or Candy B, neither are yet named as Rico defendants; however, after further
6 investigations and discovery, it seems quite likely that one or both are criminally involved with the
7 RICO defendants named herein, and are in actuality active and crucially important participants
8 in Gans enterprise and have been for many years. Remington has had serious problems
9 emanating from the file room as explained further below, since 2008 and especially since 2013.
10 The problem with Liz Smith was the extreme prejudice that she deliberately perpetrated upon
11 Remington over numerous pedantic and administrative issues, which caused her not to file several
12
13 documents and also not to return them to Remington on a timely basis to correct them.
14 Rather than just courteously call Remington on the phone immediately to leave a message for
15 him to pick-up the purportedly improperly prepared documents, and merely make the corrections
16 that she deemed necessary; or, rather than merely returning Remingtons documents immediately
17 to him by mail for correction, she did neither and elected the most catastrophic alternative on more
18 than one occasion. Instead of filing them, forwarding them on to the judge what she did was the
19 worst alternative of all: she just kept completely quiet about the issue for a week until the filing
20 deadlines had passed and until the day of the hearing to alert Remington to the problem. At that late
21 time it was nearly impossible to get the documents before the courthouse closes on its early
22 schedule, properly and timely make the corrections (which were stupid and unnecessary in the
23 first place) and then get them back to the court before the actual day of the hearing. Giving the
24 judge a few minutes before the hearing to read the documents of course was also impossible,
25 however in most of these cases Remington eventually did get the documents to the court, and then
26 said court who was 2 to 4 months behind typically what eventually read the documents at a later
27 time. Since more than 50 pages have been submitted to the state court and filed there, about this
28 topic, Gans, Plotz and the entire RICO enterprise are fully aware of this felonious situation,
Remingtons views thereon and what little the Superior Court has actually done on this matter.
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1 Therefore, 10 more pages are not needed here, but if we can discover who the felon document
2 tamperer is in the courthouse, that will be a cataclysmic and conclusive defeat for the RICO
3 enterprise, which would likely have a war ending result similar to dropping two atomic bombs on
4 Japan in 1945.
5 However, since variations on this problem occurred about a dozen times over several years,
6 several Remington motions did not get timely replies to defendants oppositions, or defendants
7 motions did not get timely oppositions in other instances, all of which greatly prejudiced
8 Remington.
9 Remington considers Liz Smiths and Candy Bs alleged actions deliberate sabotage and in
10 several cases they arose to the level of felony document tampering and "obstruction of justice", etc.
11 Overall, the illicit and believed corrupt activities of those file clerks made filing any Remington
12 document an adventure and certainly a living hell usually.
13 This file clerk document sabotaging was a long term and complex problem, which has often
14 been raised with several judges and several court executives including Linda Carter, Lisa Chapman
15 and Kerri Keenan.
16 All of those three (3) helped to solve the problem completely for brief periods, but then a few
17 months later someone would again unclip Remington's motions or large volumes of judicially
18 noticed documents, shuffle them together or scatter them around the file room or courthouse, so that
19 no one, least of all Remington could decide or determined what had been filed, what was properly
20 distributed and what was totally lost or destroyed. The last and most egregious example of
21 document scattering occurred in 2014 wherein more than 1000 pages were not sent to two different
22 judges in some remained in the file room. After several hearing deadlines had expired, Liz Smith
23 called Remington at one point and asked what Remington wanted to do with 4-500 pages of various
24 Remingtons documents sitting there, as though they were extras of some sort. Remington
25 explained that he had sent no extras of anything and that two different judges were supposed to
26 have been sent more than 1000 pages each! It then took at least a month for Kerri Keenan to
27 inventory and index all the dozen or so individual document titles, and several thousand pages and
28 determine whether Judge Watson and Judge Reinholtsen each had the full set that they were
supposed to have. Happily in that instance, defendants disqualified Judge Miles who had also
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1 received a full set of these documents late, but as it eventually turned out there was an extra two
2 months there to sort all this out. Judge Reinholtsen believed that he that eventually received all
3 documents, however Remington is not so sure. All of that was very traumatic for Remington, as a
4 key and crucial summary judgment opposition, which does not get to the judge until several days
5 after the scheduled hearing date is not optimum. Some judges like to read, study and understand a
6 complex summary judgment motion a few days or hours before the oral hearing and not several
7 months later.
8 Remington has alleged for many years that Gans and/or possibly Joy Mathson has a spy, such
9 as a child or other relative working as a saboteur in the file room, who gets paid and/or bribed for
10 doing those felonious acts several times every year. No one has yet been caught, and none of those
11 named herein have been positively implicated by specific evidence, but we are still searching for it
12 here.
13 Circumstantial evidence seen, evaluated, with all proper inferences drawn there from, by
14 Remington, which has satisfied him in the past, infers that probably Liz Smith is not the a little bit
15 too helpful "friend" that she sometimes portrays herself as being, and is known to have severely
16 damaged and/or almost terminally prejudiced several Remington's filings in the past, as described
17 above. That does not yet prove that she has committed criminal acts against Remington and his file
18 documents.
19 However, unquestionably someone has sabotaged Remingtons documents repeatedly for many
20 years and presumably has been very well-paid to do that because they are risking serious prison
21 time.
22 However, exactly who was bribed, who was paid by Gans or his staff or WHO may be Joy
23 Mathsons sister-in-law or friend of Joys daughter, is not yet known. This has been a huge and
24 horrific problem for Remington, however, and he is still very upset about it, and will be pursuing
25 this issue in detailed federal discovery with as much diligence as any single issue in these cases.
26 Gans always smiles when this issue is mentioned in open court, pretends that it is trivial and is
27 obviously inwardly laughing at Remington, because nothing useful has ever been derived from
28 Judge Reinholtsen.

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1 Said Reinholtsen always listens, seems kind and interested, but never does anything about it
2 or seem to be all that concerned about it. Wheres his anger about that? Wouldnt having a
3 murderer, arsonist or rapist running around the corners of the courthouse arouse some sort of
4 emotion, where felony document tampering might be 10% as bad? To Remington, it is traumatic
5 and emblematic of the worst possible federal civil crime imaginable. Any single missed opposition
6 reply could easily lose a major case and that appears to be Gans intent. This is obviously a state
7 and federal RICO felonious crime, it is just difficult to prove who has been causing it, but hopefully
8 that will become the district attorney's top priority here.
9 Incisive, aggressive and determine discovery and motions to compel may help, but likely only a
10 serious criminal investigation will be able to correct or control a long time rampant corruption in the
11 file room towards Remington and probably towards many other Pro Pers this county. Pro Pers are
12 universally hated, that's a no-brainer and a given, however what has been going on here over the last
13 eight years, goes far-beyond that and as explained somewhat above, is obviously a felony,
14 imprisonable document tampering within the courthouse file room, which is obviously very serious
15 and entirely unacceptable. At least it would seem to be to Remington, but few others in the courthouse.
16 Remington actually makes very few Pro Per administrative and CRC formatting rule errors,
17 regarding all of the formatting rules and especially with respect to the simple 2 spacing of two
18 holes, as punched by standard rigid two-hole punches, for the standard length two-hole fitting
19 aluminum clamps, etc. Its not rocket science and the rules are clearly delineated, Remington is
20 well-familiar with them and they are generally easy to follow.
21 As above, Remington is going to focus very hard on the Superior Court document saboteur
22 and whether it's Liz Smith or Candy B, or possibly someone not yet on the radar remains to be
23 seen.
24 K. Candy B is another biased file room employee, who doesn't like Remington clearly,
25 probably doesn't like any Pro-Pers and like Liz Smith above personally prejudiced Remington
26 severely several times with non-filings of various personally or mail-filed motion documents of all
27 sorts, in over 10 total cases. All of the rejected filings were for very important and time sensitive
28 documents and the failure to file them prejudiced Remington in each case, and with several
different judges.
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1 Remington has made several hundred filings total in these cases, and thousands in his total
2 career. Mistakes can happen, but not very often and the kind that has prejudiced him in the
3 Humboldt County file room, were not his mistakes but were a deliberate attempt by someone to
4 injure Remington and cause him to forfeit his cases.
5 Similarly to Liz Smith, Remington and various investigatory court executives have suspected
6 her, interviewed her, guided and/or possibly "admonished her" and always after these public
7 investigations things improve for a while but then after several months or even up to a year,
8 something drastically detrimental always occurs again. As above, Remington believes that someone
9 is being well-paid to risk imprisonment for these felony document tamperings, and obstructions of
10 justice, etc.
11 However, with an unstable party such as Joy Mathson involved, plus a lot of Mathsons
12 frenzied, crazy and/or unstable siblings, daughters and relatives around here, it is easy to postulate
13 that someone may be sabotaging Remington's documents just for the sport of it, BUT also to
14 absolutely insure that the Mathsons WIN their case, no matter what it takes.
15 Someone is certainly taking a Gigantic risk here and has been doing it for eight years!
16 Arguably, the file room mole, saboteur or crazed Mathsons zealot is the most intriguing and
17 interesting mystery in this case, and at least is intriguing and corrupt as the Brisso-LAFCo-Martel,
18 et al connections. Everything else now seems pretty obvious, very contaminated and will eventually
19 be remediated. Remington also expects to be reasonably compensated for many of his damages,
20 although the 10 lost years of his golden years, with his in-laws, his highly embittered, but still stoic,
21 supportive wife over this never-ending litigation, and with his three darling granddaughters in
22 England, is obviously irreplaceable at any cost.
23 In conclusion as to this issue, both of the above file room clerks are potentially primary RICO
24 racketeering enterprise members and prime defendants. However, we are going to need some actual
25 positive proof and potentially a witness that has observed this going on, or someone like McBride
26 or Plotz is going to need to come forward and positively incriminate the anti-Remington felonious
27 saboteur that resides in that courthouse. Information that leads to the arrest and criminal conviction
28 of said above court house file room mole or saboteur would go a long way towards some of those
Mitchell firm co-conspirators getting- off very lightly here. In fact, left to Remington, information
250
1 leading to the capture and conviction of the file room saboteur could result in complete exoneration
2 for someone, at least in Remingtons opinion.
3 Damages from these document tamperings have been considerable. Extreme emotional
4 distress, worry, anxiety, fear, anger were all caused by said file room saboteur. Remington made
5 numerous heart-stopping last-second attempts to duplicate documents and race down to the
6 courthouse before breakfast or before closing times, to try and get numerous oppositions or Replies
7 to department eight before hearings or decisions. There have been actual cash cost involved but
8 mostly was a loss of quality of life and overall anxiety every time Remington attempted to file any
9 document for about nine years. If any of these documents failed to reach the court in time,
10 Remington could have lost $75,000 to 200,000 at any time for any number of reasons, when his
11 whole case was defaulted or dismissed. Potential damages greatly varied with each filing, of
12 course, but were always potentially very serious to Remington cumulatively, and today are not
13 really compensable with mere dollars.
14 L. Judge Reinholtsen. Although apparently disqualified in DR140426, his present status
15 in DR080678 is ambiguous and unknown because the court clerks have not
16 communicated to Remington what happened at the hearing on November 15, 2016, AS
17 THEY WERE INSTRUCTED BY THE COURT TO DO, on November 15, 2016. Another act
18 of sabotage?
19 That would be a typical occurrence, and probably Remington has been removed from the
20 courts service list yet again, by said above saboteur. The information which Remington was sent
21 apparently by clerk Mary D, said that "The court directed that a copy of today's court minutes be
22 sent to plaintiff", but of course nothing has been sent more than 2 months later. There are few
23 occurrences in the state court system in a more prejudicial than not receiving judges decisions
24 which affect forward planning and all case activity.
25 Remington is too busy now to worry unduly about that, however it is still conceivably
26 possible that Judge Reinholtsen will voluntarily remain as the trial judge in some of these state
27 contamination cases going forward, however the following possibly somewhat intemperate,
28 imprudent and/or somewhat in-judicial remarks still are going to be made in the interests of justice,
and in furtherance of this RICO case. Remington has a weakness of candor, even where it is
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1 inconvenient sometimes. Here, as explained below, Remington has numerous serious reservations
2 about the neutrality of Judge Reinholtsen, which now for better or worse need to be investigated as
3 thoroughly and rapidly as possible in this federal case. Ideally, the state cases will be stayed during
4 that time, but if not Remington expects to continue telling the truth and trying to do what is right in
5 any case, and if that leads to prejudicing the court in some sort of resulting dismissal of the state
6 cases, then that will be dealt with at the appellate level at the appropriate time.
7 Remington filed two disqualification motionsIn Humboldt Superior Court during September
8 2016, which explain pretty much what his complaints are. The CCP 170.1 peremptory motion of
9 disqualification was denied and it appears that Judge Reinholtsen wants to continue on here, biased
10 and prejudiced against Remington or not.
11 Remington's 170.6 this qualification motion for cause was also eventually denied by Judge
12 Daum of Sonoma County.
13 Therefore, the real, actual status of major longtime case DR 080678 is "today" unknown.
14 Hopefully, in early 2017 this case in federal court will be active an ongoing and both of the state
15 cases will be appropriately stayed pending actions here. However, if not, Remington easily can and
16 definitely will file this RICO action in state court appropriately modified and deal with Gans
17 racketeering enterprise that way. It rightfully belongs in federal court and hopefully will remain
18 there where it will be better prosecuted for many different reasons. One of them is that Humboldt
19 County is grossly under-staffed with highly competent judges, who are smart and technically
20 sophisticated enough to deal with this scientifically oriented, heavily physics and chemically-based
21 contamination case. Also, there are none who actually have the time to handle these motions in
22 trials on a timely basis rather than 3 to 12 months late, for year after year, and that would especially
23 applied to Judge Reinholtsen.
24 Another major issue CRUCIALLY important to Remington, is that both of his presently
25 ongoing state cases, plus this RICO enterprise lawsuit are very heavily ethically based and also now
26 criminally oriented. Simply put, all of these cases now HEAVILY involve and actually focus on
27 criminal vandalism, obstruction of justice and multiple perjuries, plus other highly unethical
28 conduct by Gans, which is been complained of for at least three years previously, and long before
any RICO enterprise lawsuit was contemplated or even understood.
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1 Remington believes that to properly adjudicate these cases now a judge of above average moral
2 and ethical character is required in the interests of justice, and any judge with any ethical clouds
3 hanging over their heads would be unfairly disadvantaged, and in fact questionable and
4 unacceptable to Remington overall. How can a possibly "corrupt" Judge, at least in the eyes of the
5 law, if not in reality, properly adjudicate a sensitive ethical and criminal case involving obstruction
6 of justice and perjury whether under oral or written perjury? Simply put, without going into every
7 single detail of this problem, Remington is just not comfortable arguing against Gans and his
8 numerous witnesses who committed multiple felony perjuries in their recent 2016 trial, before a
9 judge who is potentially awaiting an indictment for the same offense. It just doesn't make sense, and
10 it is hard for Remington to advocate that way. Further, at this point after more than eight (8) years,
11 Remington needs a very smart and 110% honest and ethical judge with moral character that is
12 totally above reproach. We need a judge that has never committed any perjury or anything close to
13 it in his career, so that said court in this case will have the proper moral authority to administer
14 these proceedings and gain the absolute respect of all participants. Not to mention the fact that it
15 would be nice for the court to actually be honest and in essence "at least even with the law if not
16 above it. Remington now needs a judge in these cases that is more honest and more above
17 reproach than an average judge, and not something less. Ideally, in the federal system, we will be
18 assigned a judge who has an extremely strong ethical compass where perjury, violating court
19 orders or routinely defrauding the court with mischaracterizations and unbalanced, intentionally
20 inaccurate citations, will not only be totally unacceptable, but will not be tolerated, watched for and
21 punished if an attorney violates ordinary truthful ethical norms.
22 Nevertheless, if this case somehow gets bounced out of federal court, then we will file it up
23 here and make the best of whatever judges that are assigned to it.
24 Another potentially highly awkward and untenable situation will be with regards to this RICO
25 case and the imminent local district attorney's office investigation, which should begin shortly. Said
26 District Attorney's Office is already supposedly investigating the one or two judges which are
27 possibly and probably presently still involved in Remington two active state cases up here in
28 Humboldt County.

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1 Is it possible and legally tenable for the Humboldt County district attorney to be investigating
2 the defendants in Remington's RICO enterprise case while simultaneously investigating the two
3 Humboldt County judges who are attempting to adjudicate Remington's cases, including one or
4 possibly both of which could turn into RICO cases? Now in January 2017 the inference is that only
5 Judge Reinholtsen is involved again in Remingtons two state cases and that is potentially a
6 problem. However, in March, 2017 it appears that Judge Wilson will eventually be handling
7 DR140426, however Judge Reinholtsen insists on continuing DR080678 to its erroneous and bitter
8 conclusion in favor of his long time beloved fellow law partners and Gans RICO enterprise
9 members, especially Brisso.
10 That would not make good ethical, scientific or logical sense to Remington and it is another
11 argument for this court to assume jurisdiction in San Francisco federal court, to avoid these above-
12 referenced very serious conflicts of interest, judicial propriety and general common sense, among
13 many other things.
14 Furthermore, if any of this gets into the public domain, as it is certain to do electronically in
15 the next few months, trying to resolve this RICO enterprise before Humboldt County Superior
16 Court judges who are also potentially under indictment for PERJURY, obstruction of justice
17 criminal financial irregularities and the exact same kinds of charges involved in Remington's RICO
18 lawsuit, is going to be untenable, and therefore it just doesn't make a lot of sense to Remington.
19 Presumably it won't make sense to this court, or to any of the other NON-CRIMINAL (at least)
20 participants, either.
21 As above, since about 2012 Remington's cases have heavily emphasized Gans dishonesty,
22 perjury and lack of expected and required California attorney ethics, but no courts, so far seem to
23 care much about that. Especially Judge Reinholtsen, who has his own severe ethics problems, as he
24 himself has been under potential felony indictment for at least two years. Remington has written
25 scores of pages about Gans specific ethics violations and/or extensively railed orally about same,
26 only to be greeted by either total silence, or perhaps worse, at least twice in summer 2016, Judge
27 Reinholtsen said: "Mr. Remington, I don't want to hear that". Each time there was serious anger in
28 his voice and the inference was that he would not hear it on the record against this friends and
former law partners Gans and Brisso, so shut-up about it. Remington did just that and his cases
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1 have suffered drastically as a result because most of what Gans says and uses in his writings is
2 dishonest and/or false and thus Remington has needed a high integrity judge here, and now in
3 federal court, for several years.
4 In Remington's 18-page 170.6 disqualification motion, Remington disclosed his research
5 which showed that the present Mathson-side defendants attorneys fellow law-partners for
6 something like 18 years, had a very close association then and are still good, close and presumably
7 social friends, at times. NOW, appears to have become such a "time".
8 Gans and Brisso run their criminal RICO enterprise collectively and after Remington worked
9 very closely, personally, freely and candidly with Judge Reinholtsen every day for about three hours
10 for nearly 100 straight days, Remington is intuitive enough to have noticed the 180-degree change
11 in Judge Reinholtsen around mid-June 2016. Around that time Judge Reinholtsen went from being a
12 clearly neutral an entirely excellent judge, with about 85% favorable rulings to Remington in the
13 prior two years, to suddenly at least 98% negative towards Remington and favorable towards
14 defendants. That change was very dramatic, very sudden, very prejudicial, actually occurred during
15 the hearing on unknown day, and led eventually directly to the 170.6 motion at Remington's
16 earliest possible convenience.
17 Maybe Judge Reinholtsen is, was, but is not now biased against Remington. He is a very nice,
18 kind old man, a lot younger than Remington actually, and he did say repeatedly with regards to his
19 most crucially prejudicial ruling against Remington: "Maybe I'm wrong on MIL #20, and if so the
20 appeals court can decide". Remington believes there is no doubt that he was wrong on that
21 collateral estoppel granting which essentially trashed the majority of Remington's most significant
22 contamination case issues and about a dozen credible scientific test results, and that eventually he
23 will prevail upon appeal. Judge Reinholtsen's surprise reversal of his former correct position,
24 which was reasserted over four years, as to the applicability of collateral estoppel in the state case,
25 was a diametrical reversal of his own carefully calculated and well thought out summary judgment
26 decisions that he had twice made the opposite way over a four-year period.
27 When the state cases resume, Judge Reinholtsen needs to fully immerse himself in the 50 or
28 more cases that Remington has cited which proves that migrating hydrocarbons and water are not
necessary to prove a continuing nuisance or trespass case. In other words, a continuing nuisance
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1 with damages for the previous three years only and no statute of limitations can occur in
2 thousands of different non-subterranean hydrocarbon subject areas, which do not involve or have
3 anything to do with underground migrating hydrocarbons.
4 Although we DO have the latter here in reality, even with Judge Reinholtsens prejudicial and
5 perceived wrong MIL #20 ruling which illogically denies the existence of all proven test data on the
6 property here for 10 years, and all sworn depositions confirming that evidence; nevertheless, with
7 merely migrating asbestos particles, bacteria, and continuously eroding, sliding and changing
8 unstable defendant-filled debris on Remingtons land, whatever it may consist of, those materials
9 meet all Mangini, Starrh, and Escandon (varying over time) etc Supreme Court criteria for a
10 continuing tort. In other words, despite what Judge Reinholtsen apparently believes that this time,
11 Remington argues and asserts absolutely that he still has a continuing nuisance and trespass tort
12 here on his land and in any case it is up to the jury or trier of fact sitting as a jury to determine what
13 exists here, and whether it meets the legal criteria of a California continuing nuisance with no
14 statute of limitations. It is improper and unlawful for the state court to arbitrarily determined that
15 these cases are over and under the MIL #20 ruling, right or wrong, Remingtons cases are there for
16 over. That would be error, which we will appeal at the proper time however that does not appear to
17 be today. First we need another contamination jury trial for them to determine whether it is
18 reasonable or not for defendants to remove whatever it is that they did admittedly and unlawfully
19 deposit here, without any claimed permission. Furthermore, it would be absurd for defendants to
20 now attempt to assert that Remington permitted them or wanted them to contaminate and ruin his
21 property with millions of pounds of hazardous wastes including concrete chunks so huge and heavy
22 that they may not even be removable with a huge excavator.
23 Judge Reinholtsen's now perceived prejudice against Remington began that way and then
24 snowballed from there. Remington bravely and congenially tolerated more than 100 nearly
25 consecutive negative evidentiary decisions, denials and more than 100 MIL denials, but at some
26 point and objective outside observer would probably determine that all of the consecutive negative
27 decisions reflected some kind of actual and REAL bias. Remington's disqualification motions were
28 not just based on negative decisions but on actual evidence of bias.

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1 Although something of a "chicken or the egg" logical situation, are continuous and consecutive
2 negative court decisions caused by unconscious bias, bribery or some sort of unfair predilection
3 towards one side or the other? Do natural, fair negative decisions just produce the false appearance
4 of bias, after a judge decides which party is the good guy and which one is the bad guy, who he
5 cant stand or believe?
6 Anyway, that will be an issue for others in the higher courts to determine. Remington
7 believes and knows that he can tell the difference between neutrality and blatant bias, or someone
8 who may have been bribed was some sort of positive inducement to get rid of Remington and his
9 case quickly, however ultimately whether that actually occurred here will be a matter for factual
10 determination by wiser and more neutral parties than the Pro Per Remington is or perhaps could
11 ever be.
12 Remington cannot yet and therefore does not allege or even infer that Judge Reinholtsen is a
13 RICO enterprise member at this time. He first must be implicated by at least one other suspect at
14 the Mitchell firm, and presumably by one of the others named herein. Without a doubt, however he
15 will be watched for the next several years to see if he appears suddenly merrily working back at the
16 Mitchell firm again next to Gans and Brisso were he first started out. As soon as possible, we will
17 also be seeking a sworn statement from him declaring that is never gonna happen and that Brisso
18 and none of them have improperly influenced him with promises of future work after he retires
19 from the state Superior Court system.
20 As relating to Judge Reinholtsen in the above quandaries, there are many other subjective
21 factors to consider, such as: He is obviously nearing the very end of his Superior Court career and
22 almost certainly could not run for reelection; He has been under very serious consideration for
23 possible felony indictment for several years, and therefore could be fired, prosecuted and/or
24 imprisoned at any time; however, in deference to his outstanding service over the years it does
25 appear that state authorities and local authorities are going to be lenient with him; and finally, being
26 an extraordinarily hard worker, he is not going to go into full retirement gracefully and will need to
27 keep working at something, and returning to his former office in the Mitchell firm, to work with his
28 friend Brisso, seems much more than just likely, to Remington, who happens to be a rather
sensitive and astute observer of all those relevant participants.
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1 Therefore, at the moment Judge Reinholtsen is merely a possible suspect for having been
2 seriously and prejudicially influenced by Gans enterprise. Remington does not have any direct
3 proof of that, or some sort of quid pro quo, yet, but he does have hundreds of circumstantial
4 decisions and innuendos which appeared to support bias and/or something else being wrong, at
5 least in Remington's mind.
6 Remington has philosophical differences with Judge Reinholtsen but that does not make him
7 an enterprise member who has been bribed or corrupted with some sort of implied promise for
8 secure lifetime future part-time employment from Brisso. He may be ethically challenged now as
9 alleged in the press over his pay certifications, however that does not automatically, him an
10 enterprise member, make.
11 We have had to formulate an operative theory of that type however it is definitely not a
12 proven fact. So as above, we need much more evidence and that will include detailed stenographic
13 records of all hearing and case activity going forward, because Remington has more than 30 serious
14 questions at this time to ask on the record, as to how we can possibly proceed with all this next.
15 However, since Judge Reinholtsen has always treated Remington with respect and he always
16 acts as a perfect gentleman, Remington expects he will be able to reciprocate in kind and if that is
17 Judge Reinholtsens wish then we can hopefully work together civilly and objectively, at least until
18 these cases are stayed again during the federal proceeding which pretty much covers all the
19 outstanding state issues, and probably can resolve them in a timely and efficient manner.
20 Obviously, at the proper time Judge Reinholtsen will need to be deposed along with many of
21 the others mentioned here. Meanwhile, Remington merely considers Judge Reinholtsen to be an
22 unnamed possible fringe member of the RICO enterprise, who may be entirely innocent, innocuous
23 and possibly or conceivably even falsely accused by insinuation here. On the other hand, Judge
24 Reinholtsen would be obviously hypocritical to attempt to enforce stringent ethical standards on the
25 Mitchell firm, and hence decided long ago not to pay any attention to Remington's ethical
26 allegations against Gans and Brisso. Judge Reinholtsen egregiously failed to maintain the highest
27 ethical standards in his own career and sworn documents, undoubtedly for valid reasons given his
28 conscientiousness and workload; however, he is plainly put in a very ambiguous and difficult
situation to try to make hundreds of important ethical decisions in this case involving perjury,
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1 subordinating of perjury, false declarations in all of the things which Judge Reinholtsen is alleged to
2 have violated himself.
3 Simply put, it would be an unfunny "joke" to put Judge Reinholtsen in charge of a state
4 RICO case against Gans and Brisso, and hence that possibility is not even being considered by
5 Remington and he will try very hard to make this work in San Francisco federal court. Many judges
6 have been disqualified in Humboldt County, essentially by Gans and the Mitchell firm, or by
7 themselves. There appear to be no other available, qualified and/or fully "ethically clean" state
8 judges in this county interested in hearing this RICO case, and therefore it is urgent that it be heard
9 in federal court and not dismissed as defendants will very vehemently urge. They will urge
10 dismissal and transfer to state court, because they know there is no state judge in Humboldt
11 County that can justly and expertly adjudicate a RICO case against the Mitchell firm.
12 Finally, Don Corleone had "all of the New York judges in his pocket" and the other "family
13 members" wanted in on the deal. Bribery of judges is not a new concept, but is an old, established
14 custom especially among friends and smooth, sociopathic attorneys and power-brokers in all fields.
15 There's nothing unusual about bribing Judge Reinholtsen, and maybe defendants did it and
16 maybe not. Another primary alternative is that Gans and Brisso extorted Judge Reinholtsen,
17 inciting fear in him by either intimating or threatening that they would complain further to the state
18 district attorney who is already investigating Judge Reinholtsen, and theoretically they could
19 threatened to make further convincing and conclusive complaints that might get Judge Reinholtsen
20 fired immediately.
21 To Remington there is a threshold appearance of either bribery or extortion, and in actuality
22 in this case Remington believes there is a strong likelihood of some form of extraordinary influence
23 or pressure since defendants and all of them, especially Allied and the entire enterprise, as Gans
24 VERY candidly, and forcefully told Remington in the courtroom corridors, are very, very angry at
25 Remington. Angry enough to do or try anything, in Remington's opinion.
26 Remington is not accusing Brisso or anyone of giving Judge Reinholtsen $10,000 or $1
27 million to screw Remington and get him "out of here", but after carefully watching the dynamics
28 between these participants every day, for many months, the Brisso & Judge Reinholtsen
conversation probably went more along the lines of: When you retire, whenever that is, we
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1 certainly would like to have you back at the firm for as many hours and years as you like, and that
2 offer is open now or anytime and you can name your salary in affect, whenever you're ready".
3 Meanwhile, just keep doing what you're doing and act like you are "one of us" already, which
4 is an apt characterization of what Judge Reinholtsen appeared to do after approximately June 20,
5 2016, or whatever exact date it was, which is available from the records. A full-fledged card-
6 carrying member of the Mitchell firm would never have made anymore prejudicial rulings against
7 Remington the Judge Reinholtsen did from June through August 2016.
8 Among sophisticated attorneys, former law partners and high level decision-makers with a 20-
9 year or longer close legal association, former successful partnership, in a current relationship of
10 total trust, no quid pro quo was needed or offered, as it was merely obvious that the very difficult
11 and agonizing collateral estoppel decision, which Judge Reinholtsen struggled with for many years,
12 would be the conclusively pivotal factor here. Probably that does not need to be spelled-out further
13 now, as all of these top level enterprise members and the attorneys who have read these cases, and
14 who are reading this statement, should easily understand how significant and important that
15 collateral estoppel decision was here, and in any case have more than enough information from this
16 RICO statement to understand what the charges alleged against them are.
17 Judge Reinholtsen's "collateral estoppel granting" did nearly make or break" these cases,
18 under ordinary circumstances; however; in this case there were and still are many more factors to
19 consider in a successive and continuing California nuisance/trespass case. Happily, the federal
20 collateral estoppel decision based on the perfunctory 2011 Magistrates technical Summary
21 Judgment granting, and all those unconsidered variables, 99% of which the Magistrate did not need
22 to dismiss Remington's five federal statutory causes of action, were not totally conclusive and NOT
23 fatal to all Remington state causes of action, going forward. Remington maintains that the
24 Magistrate deliberately left all of Remington state causes intact FOR consideration and final
25 decision in Humboldt Superior Court; however, Judge Reinholtsen decided to take the grossly easy
26 way out, and attempt to mimic and duplicate the Magistrates total destruction of Remington's case,
27 based on Rule 26 and 37 (b) federal expert disclosure law, entirely inapplicable in state court.
28 Everything Judge Reinholtsen did in this regard appears to be wrong and based on
misunderstandings a federal law and what the Magistrate actually did in his summary judgment
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1 determination. Apparently, Judge Reinholtsen based his illogical and entirely unsustainable
2 collateral estoppel decision upon entirely non-applicable federal summary judgment disputed fact-
3 determination law, (as per Remington's thorough and extensive applicable federal and state
4 citations, provided to Judge Reinholtsen at the time), and then totally misinterpreted the
5 Magistrates summary judgment order in Remington's opinion. What facts, if any the Magistrate
6 "found", as opposed to what was mere obiter dicta, was never accurately determined in Superior
7 Court and will need to be more authoritatively determined, documented and cited by wiser and
8 higher specialists in that area of federal law.
9 However, said collateral estoppel decision was not helpful, obviously, and Remington
10 believes that it was totally wrong. In any case, it will be appealed as needed when the first state case
11 gets to an appellate court, unless that error has been rectified in this court as requested.
12 Remington cannot yet prove it, but is now arguing herein and will attempt to gather evidence
13 during discovery that cumulatively Judge Reinholtsen is suspected of at a minimum of violating 18
14 USC 1951 and 1503, and possibly several other federal statutes. He also may be entirely
15 blameless, without guilt or fault, and if so should be exonerated over the next couple of years of
16 federal proceedings. For now, Remington merely introduces the suspicion, possibility and a portion
17 of the relevant evidence.
18 Remington has documented several dozen other perceived Judge Reinholtsen "errors" to
19 appeal at the proper time, including without limitation:
20 1) Denying Remington permission to amend his complaint before or during trial to conform
21 to the actual trial proofs, many years of comprehensive expert depositions which occurred after any
22 Remington complaint in DR080668, and in general to memorialize the massive and total
23 evidentiary changes which occurred over the previous eight years, was an enormously prejudicial
24 decision. A full eight years of new, important and entirely conclusive facts were discovered in the
25 eight years prior to trial and Judge Reinholtsen would not allow any of them into Remington's 2016
26 trial complaint, NOT ONE!
27 2) After the erroneous jury verdict in the 2016 SOL trial, apparently Judge Reinholtsen thought
28 that all of Remingtons cases were there by over, despite the fact that both of his cases were
continuing trespass and nuisance cases which have no statute of limitations, and are intended to
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1 recover damages for the three years prior to their filings. The controlling Supreme Court law on
2 those topics could not be clearer and the jury is required to determine if Remingtons continuing
3 nuisance and trespass can be remediated at a reasonable cost. If so, it is and was an abusive of
4 discretion for Judge Reinholtsen to summarily decide that Remingtons cases were over, and that
5 therefore Remington did not need any time to oppose Gans motion to dismiss which had been set
6 for August 20, 2016 until Remington objected to that. In any case, that is what Judge Reinholtsen
7 attempted to do, but was delayed from doing by Remingtons two disqualification motions and now
8 by this federal lawsuit;
9 3) Judge Reinholtsen inexplicably denied any use of all of Remington's 2003 Skillings rebuttal
10 evidentiary photos, which Remington attempted to use entirely for impeachment purposes only, but
11 any use was disallowed. To Remington that was potentially an unlawful obstruction of justice and it
12 effectively killed his SOL case by itself, although another 10 similar extremely adverse decisions
13 might also have accomplished the same purpose, either individually or in groups of 2-3;
14 4) Judge Reinholtsen also barred all of Remingtons many valid and critically important special
15 jury instructions and elected to instruct the jury with bad, incomplete (as to the discovery of
16 underground buried debris and related crucial issues) and prejudicial jury instructions were used.
17 Also the jury was erroneously barred from any comments about pollution, concealment of the
18 breeze or what reasonable notice meant regarding whether a little bit of clean dirt running down
19 the hill was sufficient warning to put a reasonable person on notice to spend 20-$50,000 to see if
20 there were any unexpected and invisible hazardous contaminants in said few wheelbarrow loads of
21 clean dirt;
22 5) Numerous trial rulings appeared to be biased and totally prejudicial, such as permitting the
23 use of an unsigned and obviously defective Remington deposition, prejudicially bungled by Marcie
24 Conn in 2010, which was at least 50% mistranscribed on most pages, rejected contemporaneously
25 by Remington and his attorney but inexplicably fully allowed by Judge Reinholtsen in August 2016;
26 6) Judge Reinholtsen also prevented the full use of Mathsons Special Interrogatory number
27 Two, and again inexplicably DENIED Remingtons motion to show it to the jury;
28

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1 7) Does Reinholtsen made something like 40-80 consecutive favorable evidentiary rulings
2 towards his former law partners, Gans, Brisso and Plotz and many of them were Remington
3 motions or requests which should have been granted;
4 8) The court allowed gans to use his improperly disclosed asbestos expert Mr. Schwartz despite
5 being disclosed late and never visiting the properties until at least a month after discovery close;
6 9) The court refused to allow any deposition of Morgan Randall, despite the unethical
7 surprise which Gans employed and despite the fact that it was many months if not years before
8 trial;
9 10) The court continuously failed to recognize the significance of the twin 6 inch drainpipes
10 and the material perjury by Gans, Mathson and all of their experts regarding it. Remington
11 repeatedly requested, argued and even begged for one short special investigation of those pipes
12 by neutral environmental experts, which most likely could have ended the cases then and there,
13 however Judge Reinholtsen mysteriously refused;
14 11) Remington repeatedly showed still photographs and described dozens of hours of
15 surveillance videos memorializing John Mathsons extensive and felonious evidence spoliation,
16 however the court never recognized their significance and presumably and inferentially will next
17 bar them at the first state contamination trial;
18 12) Judge Reinholtsen would not allow any Photoshop edited photographs or even any writing
19 on them made during trial, which could be immediately erased after drawings were made.
20 Remington had more than 75 finished professional Photoshop evidentiary charts, simulations and
21 representations of his own expert testimony which have thus far been improperly barred from all
22 use and all evidence. That series of erroneous rulings makes Remington unable to present his expert
23 testimony or any of his case as he believes he should be justly permitted to do;
24 13) Remington is a properly disclosed expert on numerous topics which Judge Reinholtsen is
25 scheduled to examine him on. It now may be inferred that said court will now prejudicially prevent
26 Remington from presenting expert testimony on any subject partly so he can justify his negative
27 rulings on the Photoshopped evidence;
28 (14) During the August 2016 SOL trial Mathson stumbled at one point when he got tired and
totally reversed his sworn testimony. Instead of continuing with his false testimony that he had
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1 actually walked the fill with Remington twice (which Remington swore for two weeks never
2 happened), and that was why he knew Remington had seen it, he suddenly reversed himself, and
3 told a more accurate but still wrong version of what happened in 1998. Abruptly he stammered that
4 someone had told him that Remington had been over there, and that was the only way hed gotten
5 his knowledge on the subject!! That was a momentous change of testimony which shocked Gans
6 and Remington, however the jury missed it, not really understand the issue and when Remington
7 got a transcript of it, the court would not allow it to go to the jury. Maybe Remington did not
8 handle it properly, however that issue alone should have changed the August verdict into one in
9 Remingtons favor, however the court would not allow it.
10 (15) The court also inexplicably allowed at least 30 of Gans most prejudicial and inappropriate
11 photos into evidence which were all far out of time, meaning they were not from 2006 or earlier
12 but were from 2011 or later and were hence either essentially, or 100% irrelevant.
13 Remington preliminarily argues today and will do so with more evidence and forcefulness
14 over the next several years, that cumulatively the above pretrial and trial rulings indicate
15 something beyond bias and prejudice and perhaps involved state or federal corruption or predicate
16 acts which need to be investigated and either proven or disproven.
17 Remington has perceived and complained about many more anomalies, improper rulings or
18 believed to be judicial and unjust errors, when we get to drafting the appellate briefs. More than
19 the 15 listed above are somewhat beyond the scope here today, but will be pursued almost
20 immediately in extensive federal discovery.
21 Finally, as alluded to elsewhere in these documents, on February 17, 2017 Judge Reinholtsen
22 did conduct a hearing regarding the future direction of DR 080678 and Remington made a
23 comprehensive and legally correct argument that Mangini II and the other controlling Supreme
24 Court contamination cases now require that a jury determine whether Remington does have a bona
25 fide continuing nuisance and trespass case or not, and it is not a matter of court discretion, since
26 Remington made the proper timely informal election back during 2011. Said Reinholtsen court did
27 not permit or entertain proper motion documents on the topic where Remington would have had the
28 opportunity to provide formal written oppositions to Gans unlawful position, which is simply put
that Remingtons case is now over just because Gans RICO enterprise corruptly deceived the jury
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1 over the statute of limitations issue. However since this is not a permanent contamination case, the
2 statute of limitations is really substantially irrelevant as to where we go next in that case.
3 Although Judge Reinholtsen pretended to listen with great interest and attention to
4 Remingtons arguments, he had no questions, when questions and an honest dialogue amongst the
5 litigants would have been appropriate and expected, unless the judge had already made up his mind
6 to terminate Remingtons case and send them to the appellate court. Whether Remington intended
7 to appeal was said judges only question, which would appear to indicate the erroneous direction he
8 is prepared to go next.
9 M. Ted Kloeppel, another Mitchell firm member, apparently of a lower echelon,
10 probably also with a lower pay grade and inferentially also a non-partner, that fills-in at hearings
11 for other attorneys who are on vacation, and conspicuously he always seems to have plenty of time
12 to fill-in for Gans, Brisso or even the apprentice attorney Plotz in these cases.
13 When this section was originally drafted in 2016, Kloeppel was not believed to be quite
14 important or corrupt enough to be named as a RICO enterprise defendant, however during the next
15 two months and by late February 2017, Kloeppels name had been seen on too many conspicuous
16 case documents to believe that he is not somewhat culpable here also. He may not be as guilty as
17 the top three attorneys named here, but as compared to McBride say, after considerable inter-
18 debate, Remington decided that his legal knowledge, exposure is an equal to the other attorneys and
19 his communications with same before he made his at least a dozen court hearing appearances
20 justifies him being a RICO defendant. Just because he has a somewhat low-energy and pleasant
21 calm demeanor does not mean that he cannot be as criminally involved here as many of the other
22 defendants. Therefore, if he really doesnt know anything about the RICO enterprise perhaps he can
23 explain that, just TELL THE TRUTH HERE, about what he does know, and why he was unable
24 to learn more about this criminal conspiracy, and otherwise defend himself and talk himself out of
25 that esteemed defendant status by the time of the FAC in this case. Probably Kloeppel is in a
26 position to tell the truth and avoid the possibility of federal prison. Remington is open to that fact
27 and certainly would encourage him to come-forward and tell the truth in discovery and in the first
28 round of investigations. All we need is one RICO defendant willing to tell the truth and Kloeppel is

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1 believed to be in the top five most likely to exonerate themselves in such a manner. Obviously, it
2 will be better to tell the truth originally or first and not after being convicted.
3 Kloeppel (was in December 2016) presently NOT believed to be an active and corrupt RICO
4 enterprise member; but, he probably knows what Gans is doing and how he is deceitfully and
5 corruptly doing it. If Kloppell does not know what Gans is presently doing, he should have
6 known, and he does know now. He is an attorney in Gans corrupt law firm on the fringes of a
7 Mafia family-like criminal enterprise. He works there, he knows Gans and he knows about Gans
8 lack of ethics, laziness and inability to function at the highest level in Californias legal system. As
9 an attorney with an office a few feet from Gans he is held to a higher standard than most, and he
10 will certainly be investigated for complicity and what it does know about this racketeering
11 enterprise or, as above, should have known. And as just explained in paragraph two on page
12 255:7+ upon considerable additional thought, Kloeppel was advanced to RICO defendant status in
13 late February 2017, partially based upon the hope that he will not be implicated so deeply that he
14 cannot tell the truth NOW about what he knows, without fear of incarceration.
15 If, and WHEN, Gans eventually and inevitably goes down here, most likely when some lower-
16 level enterprise member gets scared and decides that they would rather stay home with their
17 children than possibly go to prison on Gans behalf, Mr. Kloeppel, who has never said anything
18 substantive in these cases when he made appearances for his fellow law partners, should still have
19 to fully explain himself under oath for many hours, to the district attorneys investigators. For
20 example, after reading or skimming these RICO case documents, if Kloeppel was a real legitimate
21 California attorney with real old-fashioned 1940-90 Mitchell firm true attorney ethics, he would
22 immediately walk-over the 30-feet to Gans office and cross-examine Gans, Brisso and Plotz and
23 determine what the REAL, honest truth is here in a few minutes. At that time he could come
24 forward and implicate his fellow enterprise members, but (or) most likely he will keep his mouth
25 shut about what he knows to be true, until he is implicated by someone else, or until tied to a
26 predicate act by a witness or a writing.
27 Although originally believed to probably just be an enterprise "soldier" [HOWEVER, more
28 research in January 2017 about some deceitful Interrogatories authored by Kloeppel has
advanced him to RICO defendant status for now], if Kloeppel is still there, hanging-around
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1 obliviously, innocuously and innocently on the premises when the agents come to arrest the primary
2 enterprise members, Kloppell will then have to prove his innocence, not the other way around.
3 Kloppell plays the nice friendly and somewhat dumb guy very convincingly, however he is
4 hereby put on notice that he is in the middle of a criminal enterprise, like Hitlers inner circle, and
5 very soon hes going to have to prove his innocence, rather than the other way around.
6 Kloeppel has authored many significant documents in these cases when signatures are
7 examined on the approximately 500 or more filed documents. Very quietly and unassumingly he
8 has done some significant, substantive work in these cases, especially back in 2011 on the notorious
9 Special Interrogatories, Sets TWO and THREE, etc. He may know MUCH MORE than
10 presently believed and MAY even be in the inner circle, as will be investigated.
11 Therefore, during January 2017 Remington elected to promote him into full, legitimate,
12 intentional RICO defendant status, which he could probably defend and/or defeat, if he decides to
13 tell the truth about what he knows about Gans corrupt enterprise, see pages 208-11 above.
14 O. Mischa Schwartz, defendants asbestos expert from Winzler and Kelly.
15 Schwartz started-out as merely Gans belatedly designated asbestos expert in 2011, but since
16 then has been systematically, disingenuously manipulated into an enigmatic and unethical figure by
17 Gans. Since Schwartz was designated very late, he never formally visited the dumpsites on either
18 property with the other experts, and admittedly did all his late reports far beyond the statutory
19 permitted 2011 state and federal discovery periods, and even those invalid late reports were based
20 only on photographs and hearsay observations provided to him by Mark Ferriman. Since Gans
21 strategy and script was to grossly understate the amount of very hazardous asbestos dumped and
22 buried on Remington's land, consequently Ferriman provided Schwartz with grossly deficient and
23 inaccurate data, and then Gans wrote a bogus report for Schwartz to sign based on said Ferriman's
24 95% understatement of the asbestos and chrysotile that all experts have seen here and photographed.
25 As discussed above and easily provable evidentiarily Ferriman alone personally saw more than
26 23 major samples of asbestos pipe yet reported seeing only one in 2011, and he was purportedly not
27 even sure that one was asbestos. Gans script and report written for Schwartz disingenuously
28 echoed that fraudulent volume of asbestos.

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1 Gans admitted during 2016 pretrial hearings that he brought-in Schwartz 1-2 months after
2 discovery had closed on July 6, 2011 in the state case and which discovery closed much earlier in
3 the federal one, yet Gans managed to disingenuously extensively employ Schwartz in both cases,
4 which Judge Reinholtsen conspicuously and improperly allowed to date.
5 Gans federal case successful Summary Judgment was heavily and very illicitly founded on
6 Schwartzs declaration which was based merely on looking at looking at some photos, about two
7 months after discovery had closed. When Remingtons expert reports are even three weeks late,
8 their entire contents are barred permanently. However, in Humboldt County, an attorney such as
9 Gans for whatever reason is given enormous leniency and wide latitude when it comes to deadlines
10 court rules and the numerous other complained of improprieties, herein.
11 Gans misrepresented and/or lied about Schwartz's work, especially in federal court; lied about
12 the dates of Schwartz's disclosure and whether he ever visited any of the properties in both state and
13 federal court, and Gans got away with all those misrepresentations in both courts, because judges
14 always wrongly assume that Gans is or will be an honest California officer of the court. He is NOT,
15 and as should be pretty clear by now, hes a crook, and should not be practicing law in any state.
16 In May 2016 pretrial hearings Remington emphasized the improper nature of Schwartz's
17 belated disclosure, and argued that Schwartz should not be admitted into any of the cases at all;
18 however, Judge Reinholtsen just ignored the lateness and disclosure issues and did not rule on them
19 at the time, which tacitly allowed Swartz's admission into the cases and for Gans discovery to be
20 open-ended, whereas Remington's flexibility regarding discovery deadlines, was drastically less.
21 Judge Reinholtsen's rulings regarding Maje Hoyos scientific tests completed in late December
22 2011 is highly illustrative of the prejudicial and unfair manner in which Remington was treated in
23 that regard. Remington had essentially begged Melissa Martel of the Health Department to allow
24 Ms. Hoyos to do those tests at least a year earlier, however the collusive enterprise of Martell, Gans,
25 Brisso, Esko and probably others, successfully blocked Ms. Hoyos from doing her tests on
26 Remington's and the Burl Trees property until about five months after discovery had closed. That
27 date was beyond Remingtons control, and the court could have and should have allowed those tests
28 fully in the evidence, but instead Judge Reinholtsen inexplicably prejudiced Remington further by
allowing Ms. Hoyos tests in at first, but then inexplicably and almost terminally prejudicially
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1 restricting them only to what she had done on Mathsons land. Ms. Hoyos had 5-6 single-spaced
2 pages of her reports which described her numerous observations, samples taken and tests done on
3 Remington's and the Burl Trees Land over about three years, yet strangely and prejudicially the
4 judge would not allow any of that into the case for the projected 2016 contamination trial, which
5 thankfully never went forward, without her testing.
6 When that contamination trial eventually does go forward, hopefully, we will have a different
7 judge and get a different ruling about the use of Maje Hoyos scientific tests, plus be able to use her
8 valuable, honest and neutral testimony, which therefore strongly favors Remington's case. As
9 complained above and throughout, very prejudicially, it unfortunately became crystal-clear during
10 spring 2016 that any evidence or witness that strongly favored Remington, and which might
11 conclusively lead to a Gans enterprises defeat, would be immediately and unceremoniously barred
12 or denied by Judge Reinholtsen. Sad but true, that appears to be an objective fact. Higher courts
13 will review the evidence, the trial Judges numerous decisions and perhaps conclude something
14 different, but Remington is not a total dummy, and knows what he saw and has attempted to draw
15 conclusions about its significance here, especially in terms of Gans now proven RICO enterprise
16 whose tentacles still reach very deep between the offices of the Mitchell firm and the Superior
17 Court, only three blocks apart, and also over a wider area, affecting 30-40 people at least.
18 In contrast to Remington's treatment, Gans star witness Peter Esko, described above, did his
19 report and work at least seven (7) months past the discovery cut-off, yet his work was fully allowed
20 into the case by two judges, one of whom was Judge Reinholtsen, despite the fact that it was done
21 on an essentially irrelevant adjacent property, that was not directly involved in the lawsuit nor
22 impacting Remington's land. This case is about the contamination of Remington's land, not about
23 possible contamination or lack thereof of some of the adjacent properties. Inexplicably, Judge
24 Reinholtsen has just failed to decisively grasp whats going on here for about seven years,
25 continuously delays and slow-walks all rulings and for the last 1 years has been unwilling to
26 grant or deny any motion which prejudices the Mitchell firm in any respect.
27 Simply put, all of Schwartz's work was biased, not based on a physical visit to the
28 Remington's site where all of the asbestos and chrysotile has been recovered, still exists today in

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1 various positions including still mostly buried, and hence none of Swartzs work should be
2 admissible intoEither of the presently active state cases, moving towards trials.
3 Here in this federal case it would be different, because we will have a new discovery period
4 where Schwartz and the other experts can do further investigations. That will change and add to the
5 evidence obviously, however most of the asbestos pipe which WAS visible at the lands surface,
6 plus the chrysotile cloth or insulation, has now been either well-concealed by piles of redwood
7 needles, or already been entirely removed and/or broom-swept away by John Mathson. Hence,
8 today we need to rely on the older photographs, which show the full extent of the problem, which is
9 not a surface issue, but goes 10-15 feet deep in the main body of the dump. Now, to produce
10 additional valid scientific data about the extent and severity of the contamination, we need to use
11 ground penetrating radar, miscellaneous metal detection-like studies, and related future
12 investigations on both Remingtons and Mathsons properties.
13 As related to the asbestos evidence spoliation, under the present California law, at the proper
14 time, Remington will request terminal evidentiary sanctions against Gans enterprise for his
15 ordering that John Mathson systematically remove all visible asbestos evidence from Remington's
16 property, which Mathson did do over several years. Because the California Supreme Court ruled
17 that spoliation of evidence is no longer a cause of action or necessarily a criminal felony crime,
18 various types of sanctions are about all that is left for a court to punish felony evidence spoliation as
19 has rampantly occurred here, especially in 2015-16.
20 O. Michael Pulley is Gans current surveyor who works for Points West Surveying
21 Company of Eureka California. Gans has also deceitfully and clandestinely disguised Pulley as a
22 stealth environmental volume expert, and in fact in August 2016 Pulley was scheduled to be Gans
23 most important volume expert prepared to swear to the lateral extent of the fill, it's depth and also
24 the benign and inert nature of its contents. However, under cross-examination during the August
25 2016 SOL trial he admitted that he did no independent work of his own regarding the extent or
26 volume of the fill and relied entirely on Gans and Mathsons fallacious and inaccurate
27 purported estimates which were all really written by Gans, and then fraudulently entered onto
28 Pulleys charts as though said false understated dimensions were all his original work. THAT is the
same scientific fraud which Gans has perpetrated into these cases with regards to all of defendants
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1 supposedly substantive, but really frivolous, inaccurate, and pretended to be scientific findings,
2 tests and facts from Mathsons land. In other words, most of what Gans touches is deceptive,
3 mistaken and false. Gans tried to get Pulley to present that false material as his own, but Pulley
4 refused and in so doing he preserved his integrity and presently is not even considered to be a RICO
5 enterprise member at all. He is very close, but at the moment he is merely an unfortunate associate
6 that Gans has attempted to turn bad to impressively advocate the enterprises corrupt positions, but
7 so far Pulley has resisted, and hopefully that will continue. Pulley is the only Gans associate and
8 potential enterprise member that comes off in front of a jury as being honest, and apparently that is
9 because he is honest. Therefore, Gans desperately needs him to propound some of his disingenuous
10 fraud, but so far Pulleys apparent REAL honesty has prevented that. Quite remarkable, but even
11 The Godfather, if put on trial for mass murders, could come up with a bunch of warm loving old
12 ladies and other witnesses that would be disarming in their defense of a heinous criminal.
13 Gans did not need another survey done to establish the boundary between the properties.
14 Pulley surveyed the line and drove about a dozen flag stakes along the line, but that had already
15 been done by defendants first expert Hubbard, who was paid $5-7000 for his successful efforts.
16 Remington's Farmer-paid surveying expert had also previously done a similar $7000+ survey
17 which also aligned with the other two surveys within a foot or two. In other words, the boundary
18 line was no longer an issue when Pulley did most of his work. Gans only hired him because he
19 knew that their first survey are Hubbard was a fair and reasonable person leaning morally and
20 ethically towards Remington in these lawsuits, and simply put, Hubbard refused to lie, deceive and
21 testify against Remington in any respect at a trial. That was entirely unacceptable to Gans because
22 he insists on writing a false narrative and script for every RICO enterprise witness that he uses.
23 Truthfulness and actual facts are like sunshine to a vampire, and thats the only reason why Pulley
24 was employed in this case. He was willing to follow Gans orders and in August 2016, he pretty-
25 much testified to whatever Gans ordered him to say. However, on the above virtual extent of the
26 fill and volume issues Pulley drew a disingenuous and false line that was dictated to him by Gans
27 and Mathson (as above), but when cross-examined on it he refused to lie about its source
28 information and actually told the truth, which must have seriously disturbed Gans. Simply put,

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1 because Pulley has shown a propensity to stick to the actual truth when pressed, Remington does
2 not presently regard him as an active, culpable criminal enterprise member.
3 Pulley represents another ambiguous and anomalous RICO situation. By definition, Pulley is
4 a RICO Enterprise associate and active worker, but presently, as discussed above in a March edit,
5 Remington does not consider him to be an actual RICO enterprise member, who is guilty of a crime
6 requiring punishment. Pulley is something of an enigma who was (and IS) under Gans direct and
7 corrupt influence, but when Pulley was put under oath he calmly acknowledged what he did, what
8 he was told to do by Gans and only vouched-for what he personally did, and for what he personally
9 knows to be true. That testimony was hard to find fault with, and hence Remington did not.
10 As above, one of Pulleys jobs was to survey and draw the boundary line between the
11 Remington and Mathson properties on a map. That line had previously been well-established and
12 drawn by Hubbard and Farmers surveyor. it needed to be established, but not by Pulley, who
13 potentially does much more than that for Gans.
14 Background: Mark Hubbard was defendants first surveyor back in 2008 and he appeared to
15 do a perfectly fine survey with John Mathsons assistance and they drove a bunch of flagged stakes
16 along the same line that Pulley discovered. Hubbard however would not "play ball" with Gans
17 and would not agree to wantonly screw Remington indiscriminately and indefinitely, and until Gans
18 and Mathson had stolen or extorted all or most of Remington's land adjacent to the Mathsons. Said
19 adjacent land has been wantonly used by Mathson and rent-free since 1998, with a back rent now
20 DUE and demanded of $12,000 per year for 18 years so far.
21 All Pulley was paid to do originally was to do a survey, draw-up a formal map of its results,
22 including the location of Remington's informal "agreed fence", and perhaps most importantly
23 sketch in a dotted line which was his estimate of the limits of the "toe of the fill", which is
24 discussed herein was a totally inaccurate gross understatement of how the far the fill went in any
25 direction. Pulleys estimate is not based on his own investigations but was strictly based on what
26 Mathson purportedly told him, which this means that it was word Gans said it was and no more or
27 less than that.
28 When Pulley did his map so well, exactly as dictated by Gans, and as Gans got to know him,
he learned that Pulley could and would effectively, impressively and quite obviously,
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1 HONESTLY testify to apparently virtually anything that Gans told him to and Gans originally
2 concluded that would include false representations about the extent and composition of the fill, or
3 any other mischaracterizations, inaccurate self-serving facts or related frauds which Gans might
4 script for him the same way he did for all of his other witnesses.
5 Pulley initially fully satisfied Gans deceitful intentions for him when he drew his highly
6 inaccurate map referenced above. Pulleys map shows a dotted line now, the toe-of-the-fill, which
7 he purportedly investigated and discovered himself (in Gans false narrative) about how far the fill
8 went onto Remington's land; however, the truth is, which was verified during the 2016 SOL trial, is
9 that Pulley does, did not have, and never had any a clue about how far the fill went in any direction,
10 but instead got all his total misinformation from John Mathson (which in the reality of this enterprise
11 means that Gans wrote the script) and thus the lateral extent of the fill was understated by 4-600%
12 approximately. Gans obviously did not expect Remington to cross-examine Pulley in detail on
13 that point and on the source of his information drafted onto his map, nor did he expect Pulley to
14 freely and honestly acknowledge the above. As a result of the above facts, Pulley is now a worthless
15 witness for Gans and will have little to no effect on the jury as far as articulating and selling Gans
16 false narrative about how minimal defendants encroachment is onto the Remingtons land. The truth
17 is otherwise, and Pulley is not presently prepared to lie for Gans and his enterprise. That is very
18 shocking and traumatic to Gans and now he may have to replace Pulley for the same reason as
19 Hubbard was replaced which was that they were both too honest and unwilling to follow the RICO
20 enterprises objectives of destroying Remington, lying, deceiving, misrepresenting small and large
21 things, and doing anything else that it took to damage Remington during a trial.
22 There can be no doubt now that Gans is contemplating finding a new surveyor who will freely
23 lie on the witness stand, but that would be too late now in the state cases and at some point Pulley
24 may honestly tell investigators what he was asked to deceitfully lie and testify about. That would be
25 our hope. We only need one or two witnesses to explain the details of Gans improper, unethical and
26 illegal witness tampering, script memorization and preparation, as he calls it.
27 The beauty of Pulley and the reason that Gans uses him so frequently and effectively is that he
28 has an honest, local, down-to-earth presence and demeanor, plus a loud booming voice which

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1 commands respect, honesty and just appears solid, unshakable and irrefutable. And, surprisingly,
2 that honesty is actually real and not that easily destroyed and substituted by Gans fraudulent scripts.
3 Thus, supposedly anything Pulley says is likely to be true and it is obvious to Remington that
4 he would have no trouble convincing a jury of that. If Pulley swears that black is white then a jury
5 is likely to believe exactly that. However, now that Remington has a good rapport with them and
6 understands that he is intrinsically honest we should be able to get to the truth of what he knows,
7 what he thinks, what he actually did himself, versus what Gans tried to bully him to say in the
8 pursuit of the RICO enterprises objectives.
9 Here, Pulley doesn't have a clue about how far the dump goes in any direction, how deep
10 it is or what's in it, and he is willing to freely admit that if he is asked. If hes not asked, he might
11 lower himself to memorizing a few of Gans tricks and devices. In any case what is clear is that he
12 just seems or sounds right, solid, confident of himself, and honest about everything he testifies
13 about and Remington got lucky that Pulley appears to be an honest witness.
14 Conversely, Gans is very upset with him, and is probably trying to work with him even now,
15 before he responds to federal discovery. It must have seemed initially that whatever Gans writes in
16 his script for him, that defines the dump or as concerns just about anything, Pulley could probably
17 have convinced a jury of that. No matter what the actual truth was, or what Remington or his
18 mathematical and geometrical volume analysts had properly, correctly and formerly calculated
19 likely would have mattered much too an impressionable jury. So, as above, Remington really did
20 get lucky and if Pulley is as smart as he appears he might be, he would be wise to disengage
21 himself from any future associations with Gans and his RICO racketeering enterprise, which future
22 associations with Pulley probably can only end badly, from this point.
23 Therefore, Mike Pulley today is an important, credible, respectable-looking, solid and
24 influential part-time associate of Gans criminal enterprise, who will make a good impression on
25 a jury no matter what topic he testifies about. Pulley appeared to be the only August 2016 trial
26 witness that Gans either did not write compulsory perjured testimony for, or alternatively Pulley
27 refused to testify to it. Therefore, either way he may not YET be fully aware of the full extent of
28 Gans corruption in this RICO enterprise case. He probably has his suspicions which we will probe
at his deposition and elsewhere, but probably Gans has not revealed all of the enterprises corrupt
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1 and perjurious objectives to Pulley. In other words, Pulley possibly can extricate himself from this
2 morass more easily than most that are mentioned here, and therefore he would be very wise to read
3 all these documents very carefully, and fully understand all of them, before he appears at the next
4 Gans trial and swears to anything else in these cases, again.
5 Going into 2017, Pulleys credibility problem now is that he relied on all of the false and
6 inaccurate scientific information that Mathson and Gans told him and ordered him to enter onto
7 his influential map, regarding how far the fill extended in every direction. Thereafter, Pulley did
8 permanently draft all that false Gans RICO information onto HIS survey map, below his
9 letterhead, essentially putting his professional credentials, integrity and credibility on the line and
10 now at risk.
11 Then Pulley drew a line on his map called the toe-of-the fill, however, as above, when he
12 was questioned about it under oath he did not falsely swear to the veracity and accuracy of that line
13 but did honestly acknowledge the sources of his information. Ordinarily, the legal system does not
14 punish honesty, nor does Remington. Against five perjuring witnesses in August 2016, Gans
15 perjury prevailed over Remingtons honesty, however that merely inspired and angered Remington
16 to fight Gans outrageous organized RICO corruption and injustice, wherein Gans used a collection
17 of motley and desperate witnesses that will never be able to consistently espouse those lies for
18 another few years, while risking federal prison. Who would risk federal prison Just to save Gans
19 and his obviously blatantly false and dishonest schemes? And, are the Mathsons or RAO, lily
20 white and somehow being unjustly wronged here, just because Remington wants them to remove
21 their enormously profitable hazardous waste dump from his land? Does that make the Mathsons
22 victims?
23 Therefore, Pulley going into a federal trial is in the enviable position among these near-RICO
24 defendants of having been ostensibly and essentially truthful up until this point. He was wrong to
25 blindly follow Gans and Mathson's facts and motives are all wrong or evil, however "wrong" is not
26 yet criminal. Pulley is not a named defendant, not a nearly-named defendant based on discovery,
27 and today is merely a RICO Enterprise associate who has provided a valuable litigation service to
28 Gans, but without committing any crimes yet, such as the perjury Gans had hoped for.

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1 Exactly how far the fill goes in every direction is always been difficult to determine but today
2 it is impossible because the entire dumpsite is covered with a deep layer of redwood needles and
3 other organic matter from 2 inches to 8 inches deep. Therefore the only one who knows where fill is
4 located or is not located is Remington who dug more than 500 holes across the whole dump area to
5 plant trees and to place stepping "stones", which stones are really redwood rounds from 12 to 30
6 inches in diameter. Remington initially planted bushes and trees over the entire dump area and also
7 made several major paths requiring excavation all across the dump.
8 Because defendants encroaching fill on Remingtons property is mostly several to many feet
9 deep, the only way to accurately determine where fill is located or not is by excavating from 6 to 20
10 inches deep, as in many cases defendants fill objects rolled more than 100 feet down the
11 mountain and into the creek. As of about 2008, Remington had excavated at least 2500 ft. across
12 this 20,000 ft area, which included approximately 200 2' x 2' stepping "rounds" and also two large
13 irrigation pool/tank foundation areas of over 400 ft. each, plus Remington hand dug more than 150
14 planning holes for all sizes of trees.
15 It is not possible for Pulley to accurately base any substantive opinions upon what John
16 Mathson thinks he knows or may have known 10-years ago before he removed most of the surface
17 evidence and before Remington did the above excavations which positively proved the exact extent
18 of and the exact end of the dump debris in all directions on Remington's property, which covers
19 about 180 of a circle. Exactly how far Mathsons illegally encroaching fill, located inside of
20 Remington's fence, encroaches onto Remingtons land or onto Mathsons northern neighbors
21 property, has not yet been fully investigated by Pulley and hence he is not yet expressed any
22 definitive opinion. Further, to do so when no Remington property investigation was scheduled
23 would have been trespassing and violated California discovery laws, hence it is good and also
24 illegal that Pulley never did do a comprehensive investigation of Remingtons land and instead, as
25 he admitted, he merely relied on Mathsons also unauthorized, uninformed guesses and self-
26 serving obviously grossly understated estimates.
27 Conclusion: Pulley now seems to be in an anomalous position unlike anyone else named in
28 these documents. If the enterprise falls in the next several months, probably he should not be
indicted or prosecuted. Yet, he is closely associated with Gans enterprise and he has testified
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1 somewhat deceptively initially and has written a major case document which could be construed as
2 a fraud, and that is exactly how Remington construes it. Perhaps a federal court will dismiss it as
3 some sort of innocent error, but it was pretty deliberate one it was drafted. Said map, was construed
4 as a fraud initially by Remington immediately when Pulley explained his source materials that may
5 have assuaged some of his guilt, but possibly not all of it because initially said map represents a
6 deliberately fraudulent document intended to deceive Remington, the court and the jury.
7 Probably consulting a good lawyer unaffiliated with the Mitchell organization would be a
8 reasonable exercise for Pulley because a federal court or local prosecutor might not be as liberal
9 and lenient in assessing who is guilty here are not, and easily and arguably could just split-up the
10 treble damages among all participants and associates of this RICO enterprise. Splitting-up say a
11 couple million dollars of damages among 10-20 RICO defendants and associates, would not
12 necessarily be based on some abstract percentage of guilt, even if today it appears that Gans and
13 his top 5-6 leadership members of the enterprise are at least 75-95% culpable here for all damages
14 whereas Pulley might be culpable for just a mere few percentage points of the total damages.
15 However, even that could potentially be substantial.
16 Q. Matthew Hillyard of Farallon, Inc. located in Portland, Oregon, is Gans new
17 replacement environmental expert. From Hillyards photograph he appears to be an impressive,
18 vigorous and youthful Anthony Robbins clone or look alike, who is guaranteed to make a good
19 visual impression on a jury. That impression may well turn negative however, when it is determined
20 that: Hillyard has done no legitimate individual work in these cases, in the light of day, or within
21 discovery rules that is recognized in these cases; and, that his testimony is 100% based on Ferriman
22 and Gwinns work which has been entirely refuted scientifically, further proven to be false and
23 deliberately fraudulent, and has otherwise been ridiculed and reduced to absurdity, which was why
24 Hillyard was called on the first place.
25 Gans hired him during winter 2015 because Ferriman and Blue Rock were fully discredited
26 and inferentially Ferriman, and definitely Gwinn are just too damaged now in their wrong
27 substantive opinions to be credible and useful before a jury. Also, neither can withstand a
28 credibility, credential or relevant experience comparison with the nationally recognized Dr.
McEdwards, who has an eminent doctorate and undergraduate education from the University of
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1 California at Berkeley. Remington's previous deceased expert John Aveggio will also still be
2 considerably involved in these contamination cases and his education, competence and work was
3 also very exemplary, preeminent in Northern California and noticeably vastly superior to what Blue
4 Rock did, which differences, scientific and moral superiority can be conveyed to a jury.
5 Furthermore, it was definitively established during the 2016 state trials here that Ferriman has
6 just refuse to swear to anything which Gans writes for him now because too many errors have been
7 made and too much perjury has already been written. Ferriman is believed to be too smart now to
8 commit blatant provable oral perjury in front of a jury, on a stenographic record, and if that view is
9 fully accurate then Hillyard's presence is fully explained. additionally, why would Blue Rock want
10 to submit themselves to probable RICO treble damages from further associations with Gans
11 deceitful corruption?
12 Because Gans wrote most of Ferriman's opinions for him, Ferriman has proven to be
13 incompetent, unreliable and at best a scientific whore, willing to swear to anything that Gans writes
14 for him, and now he will most likely be called as our witness in the next state or federal
15 contamination trials. However, if Gans should for some reason make the error of calling him, then
16 Remington's case will be the penultimate beneficiary thereof.
17 Right now, Hillyard is an enigmatic, mystery figure who Gans brought in more than five (5)
18 years after all discovery had closed in all cases to do some odd and unknown "borings" at unknown
19 locations, apparently very corruptly and illicitly on both Remington and Mathsons property, but in
20 any case inside of Remington's posted fence where he would have been trespassing and facing
21 "prosecution", as the area is posted, in any case. Gans sent Remington an ambiguous and
22 unintelligible letter in early 2016 threatening and extorting Remington by intimating that
23 whatever tests Hillyard did were VERY important to Gans defense. Gans specifically did not
24 divulge the location, the depths or the results of any of those tests in a specific attempt to plant
25 some sort of irrational fear in Remington, which failed, and in any event nothing Hilliard did is
26 admissible in any present case. Furthermore, Remington was present on the property on the day of
27 Hillyards tests, so why was he not informed and invited to have his expert observe whatever it was
28 that Hillyard Illicitly did, if anything.

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1 The clear inference and implication to Remington is that Gans was saying and proving in
2 effect that he can bring in an unlimited number of new, very expensive, highly qualified and
3 nationally known experts to prove anything that Gans wants to prove (or write in his fictional
4 scripts) and conversely Gans can, at any unexpected time, do tests near or anywhere that Remington
5 has done previous tests, to again corruptly refute, muddy or confuse any data that Remington had
6 gathered from past years. However, the fact has been known for years that Gans can find, pay and
7 bring in a nearly unlimited stream of scientific "whores" that will test anywhere that Gans suggests,
8 and by one means or another prove or disprove anything that Gans case requires.
9 At this point, Hilliard appears to be Gans new and ONLY remaining environmental expert
10 who will follow Gans corrupt RICO orders exactly, as per the above. However, passing through
11 here briefly for an hour from Oregon and noticing the soils and/or water flows which on any given
12 day would be no more than 10% of the dynamics which occur over a year, could not be expected to
13 accomplish a whole lot that is significant, and clearly it did not. Additionally, the steep topography
14 here, unstable slopes, continuous slides and the extreme seasonality factors present here caused by
15 Mathsons dumps unrestricted and uncontrolled water runoff, causes drastic changes in the entire
16 environment of both properties every 1-5 years. Now, Hillyards illicit breaking and entering and
17 trespassing onto Remingtons land inside his clearly posted fences, has subjected his credibility and
18 integrity to close and detrimental scrutiny. It also makes him a new RICO enterprise member and
19 imminently named active defendant when he must shortly put his investigations and work into a
20 sworn written document.
21 In early 2016 when Gans sent Hillyard's enigmatic and meaningless results without any details
22 or any locations whatsoever provided, this was clearly another mail fraud predicate act by Gans. It
23 was a blatant attempt to instill Hobbs Act type fear in Remington that somehow Maje Hoyos and
24 SHN's 2011 tests in the lower swamp area were improper, unreliable or wrong, because of these
25 unknown and unspecified tests done either uphill from or in the exact same swamp area on
26 Remington's property. Hillyards tests were inferentially done in the middle of a rainstorm which
27 obviously substantially affects hydrocarbon soil and water results, as does the season.
28 Hillyard has probably not yet made the errors that Ferriman and Gwinn made under Gans
corrupt influence, however in time Hillyards credibility is likely to go the same way as Blue
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1 Rocks. But, after Gans writes some more of his crappy, worthless reports based on defendants
2 incompetent, one-sided data, entirely from a different property not even involved directly in these
3 lawsuits, Hillyard and Farallons credibility will not last long.
4 Gans is totally stuck with Blue Rock in DR080678, although Remington does expect some
5 ingenious device to shortly be used by Gans to try to get Ferriman and Gwinn legitimately out of
6 the case, perhaps in the same way Remington lost his SHN experts. But, barring such a replacement
7 attempt, and a Gans success with that new anticipated unethical and corrupt maneuver, presumably
8 Gans will run this guy down from Portland in the next cases, at a minimum.
9 Hopefully, Gans will try that because all the Blue Rock personnel will immediately be
10 subpoenaed by Remington, and if so, and under those circumstances, they might even figure-out a
11 way to tell the truth about this enterprise. That is especially true if the district attorney asks the
12 questions first.
13 Hillyard is now part of these cases, has assisted Gans RICO enterprise, and is hence now a
14 part of and shortly will be responsible for defending the hundreds of scientifically undependable
15 frauds perpetrated by his enterprise and former experts. Happily, Hillyard, who looks like a nice
16 enough chap, has not yet been named as a RICO defendant, because he has not signed anything
17 under penalty of perjury yet. Sworn written federal discovery will commence very shortly, however.
18
Q. The City of Eureka and Public Works Director in 1998, Boyd Davis.
19
Mr. Davis, who served as public works director from 1996-2000, and the city of Eureka
20
are now named in the contamination portion of this lawsuit, because they illicitly provided at least
21
15 to 20,000 pounds of asbestos pipe, chrysotile and related hazardous wastes to RAO Construction
22
who deposited them on Remingtons land, where they remain today. Whether The City knew
23
about those crimes or should have known remains to be discovered. The city is not yet named
24
as part of this RICO enterprise, and presumably will never be because their present known
25
involvement was far outside of the statute of limitations, and was possibly beyond the knowledge of
26
any present employees. That is, of course unless Gans and Kluck get a hold of them, and attempts
27
to begin a disingenuous, charismatic and conspiratorial cover-up of their 1998 era activities.
28

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1 However, Eureka is mentioned and discussed here briefly now because: They are now
2 involved in the original contamination lawsuits and may bear culpability for the environmental
3 damages presently being experienced here, depending upon what exact contractual terms,
4 understandings and related facts they had with RAO in 1998, among other things.
5 If they now become emboldened by Gans fraudulent bravado and otherwise mesmerized by
6 his deceitful charisma in the next few months; and/or The City becomes influenced by and
7 actually begins to believe Gans corruption, lies, mischaracterizations and enterprise purposes; and,
8 thereafter join the enterprise and begins participating in Gans general minimizations and cover-up
9 of all things relating to contamination on these sites, The City could very quickly become
10 implicated here.
11 Hopefully, that will not happen, however the probability is that when the attorneys all get
12 together to oppose the obnoxious old pro per, they may just laugh at Remington and this Quixotic-
13 like RICO suit and quickly and reflexively join Gans is formerly prestigious law firm and join-in
14 and/or participate in his new almost continuous predicate acts here. If, and when that occurs,
15 Remington well amend this statement and complaint; but, meanwhile they are responsible to a
16 presently unknown extent for contaminating Remingtons land with 15 to 20,000 pounds of highly
17 toxic asbestos and Chrysotile, which came from the citys toxic asbestos water lines in 1998. What
18 contracts or agreements they had with Olson and RAO to remove and haul-away that asbestos are
19 not presently known, or yet discovered.
20 Relating to RICO, no contemporary federal predicate acts in the 2012-16 are known, or
21 likely, however, the city is charged in these asbestos and dumping crimes, and they may well
22 begin a new creative cover-up of some kind during 2017, when or if influenced by Gans, as above.
23 Here, Mr. Davis appears to be long-gone from the city, however he clearly deliberately and
24 knowingly committed a crime in collusion with Rich Olson, or conceivably could have been tricked
25 and defrauded into negligently assuming, or into negligently relying on false Olson assertions, that
26 his asbestos water pipes by the golf course, apparently along Herrick Avenue, were going to be
27 properly disposed of in a lawful facility. Discovery will determined exactly what was said, who
28 knew what when, and what written disposal agreements exist regarding that asbestos.

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1 In other words, it now seems quite likely that the city and public works director are
2 substantially innocent and were duped by the early conspiratorial and criminal hauling and dumping
3 schemes of Mathson, RAO, Randall and the other present enterprise members who are active that
4 far back, many of whom were involved here going back as far as 1998, but not necessarily violating
5 federal predicate acts that far back. Today, the facts show that only Olson, Skillings and John
6 Mathson were positively involved in their original 1990s dumping schemes. Since none of the
7 other present-day RICO enterprise members appear to have been involved at all (subject to
8 discovery of course), clearly the RICO enterprise did not exist in a viable form until about 2012, as
9 asserted here.
10 On the other hand, very clearly the City of Eureka is directly responsible for severely
11 damaging Remington as far as the present day contamination of this property is concerned.
12 Therefore hopefully they will attempt to opt-out of this contamination lawsuit, and not collude
13 and/or conspire with Gans going forward in the cover-up of the RICO enterprise, and decide to
14 assist Remington and the criminal authorities in initially going after Olson. This document however
15 is a RICO statement, involving Gans extortion, other predicate acts and essentially Gans massive
16 cover-up of their present racketeering enterprise mostly through carefully coached false testimony.
17 Thus, hopefully the City and Mr. Davis will continue to remain honest, fair and legal in
18 their representations of all their possibly illicit 1998 activities, and they will therefore determine the
19 accurate facts as they existed around 1998. Possibly, they will consistently argue that they were
20 duped by the RAO organization, which does at least appear on the surface, at the moment, to be
21 plausible. Proofs of that remain to be seen, especially what written agreements they operated under
22 at that time.
23 Rather clearly, neither Olson nor Skillings will admit that they were a criminal hauling and
24 dumping operation breaking at least 50 different types of governmental laws in the late 1990s. Also
25 likely is that they charged the city plenty, and just enough to underbid any competition so that
26 they could make a gigantic profit on a 10-minute haul that was supposed to be a 1-2 day haul.
27 Speculation here is cheap today, and now we must discover all of the accurate facts
28 regarding the transfer of asbestos and chrysotile because those are among the chief hazardous waste
problems remaining here today.
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1 For example, in case RAOs clever criminal hauling and dumping scheme is not clear to
2 some readers here, if proper lawful dumping protocols, for example hauling to Anderson, California
3 or Nevada, dictated that $2000-4000 per load was reasonable, in order to obey the law, then RAO
4 could easily bid $1800/Load and get all the local hazardous hauling jobs very easily.
5 Then, the rest was easy. A 10-minute haul to Mathsons land and illegal class one hazardous
6 residential waste dump would, at $100 per hour, only cost Olson barely 15-$20. If RAO had gotten
7 the bid to do just one load at $1800, then that was a quick 10-minute profit of $1780/load, and
8 probably tax free and under the table. JUST Imagine the kind of profit that could be made even in
9 only one day with that sort of quick profit, if there was a substantial amount of hazardous wastes to
10 haul, such as DID actually exist in 1998, with 5-6 gas station remediation projects then underway
11 along Broadway during the late 1990s.
12 Back in the 1990s, when Remington was a trucker himself (as discussed in the Skillings
13 section), he personally observed and can therefore verify, under oath or as needed, that there were
14 many hungry and aggressive Humboldt County truckers in that era with little or no ethics or
15 scruples, especially if they were really criminals at heart. Remington knew many truckers from that
16 era, including some who were super straight and totally honest; however, Remington also knew
17 truckers who would jump at that job, or any job, and HAUL 10 or 100 loads, all day and then all
18 night in a heartbeat, before anyone caught-on-to this criminal scheme. RAO, Mathson and Skillings
19 were very clever, very wary, and essentially just as fast as they hauled-in multiple criminally highly
20 contaminated loads, they daily pushed clean fill dirt over-the-top of the contamination, just like the
21 normal daily procedures of any standard landfill.
22 Therefore, reiterating: NONE of the 18 USC 1961 predicate acts within the correct SOL
23 (statute of limitations) can be, or are alleged here at this time, pending more discovery and
24 information from the 1998 public works director about what he did, when, why, what ROA said at
25 the time, what was written, what was paid, and what facts were reasonably (and not negligently)
26 relied upon, or perhaps should have been suspected and/or investigated back then, but were not.
27 Olson is very smart, at least as smart as the average clever criminal, and thats often what it
28 takes to make it as a small businessman on the north coast, above-average qualities and abilities of
many types. RAO appears to have made it, but obviously only very precariously, since they had
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1 to go into corrupt illegal hauling to really make things work. All small businesses on the north coast
2 struggle and work hard, but probably 95% of them do it honestly. Therefore, the point here is that
3 Olson quite probably tricked the city by not making too conspicuously the super-lowest bid and
4 quite probably the city relied on Olsons integrity and the default premise that all well-known,
5 credible licensed local haulers would obey all relevant laws, and would be responsible to the
6 criminal authorities directly, so the city wouldnt need to worry about it. Quite likely, the city had
7 no good way of knowing, at least initially, at least until the same truck and driver kept recycling
8 every half hour, that the hazardous wastes that they may have paid $3-5000 per load to have
9 legally hauled to distant paid, permitted disposal sites between Anderson, California and Nevada, in
10 reality only cost Olson about $50 to haul to Mathsons very illegal residential Class One landfill.
11 On the other hand, with the high degree of criminality alleged here and the several specific
12 bribes which are already suspected and alleged hear above, for example to Paul Dalka in 1998, it
13 appears to Remington that it is as likely as not that Boyd Davis was bribed, or was somehow
14 irregularly induced to provide RAO with this massive profitable project. Todays facts show that at
15 a minimum the City of Eureka should have known that Olson was conducting a criminal hauling
16 and disposal operation in the 1990s.
17 In any case, whatever is eventually discovered to have taken place in 1998, the most lethal and
18 dangerous hazardous wastes still present on the sites today came from the city, so we need to know
19 what contracts, understandings, agreements, codicils and payments were made to whom and when.
20 Obviously, we will attempt to discover more actual details, and hopefully the criminal
21 authorities will take an interest in, and do some of these difficult investigations themselves, most of
22 which are beyond Remingtons capacities and interests.
23 As a major hauler of more than 1000 irregular, huge, heavy, wide, difficult to restrain and
24 highly dangerous and unwieldy semi-end dump loads of Redwood burls himself, Remington
25 KNOWS HAULING, and appreciates exactly what RAO had to do here. Hauling heavy, dangerous,
26 or in this case toxic, dump truck loads of anything is hard and expensive. It had to be difficult. Who
27 says crime is easy and criminals are lazy?
28 RAOs constant and major nemesis would have been the CHP as well as the Humboldt
County inspectors. Therefore, Olsons chief criminal, con-man skill here, was some sort of friendly,
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1 innocuous and unsuspicious demeanor and behavior which did not attract any attention to himself
2 and his very felonious loads, unless he just bribed a bunch of people. See likely viable possibility of
3 that occurring with respect to Paul Dalka, then the acting director of the county health department
4 in fall-spring 1998-99.
5 Maybe Olson went to high school with some of the CHP on the Elk River Road beat. Or, also
6 RAO may have just known their pattern, which is no more than two (CHP) trips up Elk River Road
7 to Ridgewood Drive in any given day, one of which is generally around 6 PM. Olsons deposition
8 should be both long, fascinating and very educational in between the massive objections and threats
9 to walk-out, which will need to be often arbitrated by the federal court.
10 Meanwhile, as above, unless the city falls prey to Gans corrupt charisma, enjoys his cover-
11 up, it would appear at this time that Boyd Davis may well have acted innocently, and in any event
12 was not and could not have been part of any RICO enterprise, by definition, because it did not even
13 exist in 1998, in any case. But, Gans is certainly urgently looking for strong-handed new
14 members today.
15 Finally, as explained in the overriding contamination cases, Remingtons present damages
16 attributable to the asbestos hazards is arguably in the $200,000 range, because there was a huge
17 amount of overall debris dumped and buried here which is interspersed with a large and heavy
18 amount of specialist materials. That requires everything now to be sorted and bagged, substantially
19 by hand by workers in Hazmat suits, etc. Therefore, the large concrete, asphalt, iron, etc objects and
20 hundreds of yards of hydrocarbon gas station remediation spoils and wastes cannot just be
21 excavated on the dump trucks and hauled away. Much of it needs to be hand-sorted now, studied
22 and organize, over on the few flat surfaces available on Remingtons land, before hauling it all to a
23 proper disposal site.
24 Defendants have been unwilling to do any of the responsible cleanup that is now required
25 here. Therefore court interference is assumed to continue to be necessary here and is therefore
26 requested, as per the injunction requests in the main lawsuit. It is expected however that there will
27 soon be several new attorneys involved here and possibly they will not just automatically join Gans
28 corrupt enterprise (fraternity and/or club) to battle the obnoxious pro per Remington to the
death, and they might instead decide to pool their resources, do the right thing for the
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1 environment and Remington, before investing another several hundred thousand dollars each like
2 Lawrence, Allied and Gans inferentially, mistakenly decided to do. Joining Gans enterprise now,
3 in first federal and then state court, and continuing to support his unjust battle against Remington
4 and the contamination plainly visible here, would seem to be quite unwise now. That would be
5 because the enterprise defendants are now rolling the dice against treble damages, plus
6 potentially a lot more if a jury happens to sympathetically view Remingtons punitive, general and
7 special, etc damages (which include his major enterprise caused physical disabilities) and costs
8 requested in the main complaint.
9 As frequently alluded to above, because it is now a real possibility, significant danger, and
10 certainly a recurring fear in any case, the enterprise presently has the additional risk that
11 Remington could realistically somehow be killed here or otherwise inexplicably and mysteriously
12 wind-up-dead, somewhere along the 2-mile, lonely, traffic-free, daily night-time drive between
13 his two residences. Will Gans or Brisso order a hit to save their law licenses, prestige,
14 reputations and careers? Would anyone seriously doubt that?
15 In that possible unfortunate event, his wife, his University of Pennsylvania Law School
16 graduate-lawyer daughter and/or their children may decide that Remingtons life was worth
17 something also, perhaps even above what is requested herein. In that eventuality, also of use would
18 be her multi-million-dollar per year, big-time, high-powered London criminal lawyer partner,
19 who might enjoy participating in this on one of his numerous, very lengthy sabbatical vacations,
20 it might be able to coordinate with a federal trial here, as San Francisco would be a nice place for
21 them to spend a couple months.
22 R. Marcie Conn, the bad stenographer who butchered one of Remington's 2010
23 declarations to deliberately benefit Gans. Conn did a horrible, unreadable and unusable
24 deposition of Bruce Remington when she came down from Crescent city about an hour late and
25 under extreme emotional duress. Possibly her errors were innocent and not deliberate, however
26 when a stenographer misses, omits, but does not acknowledge doing so, a full 30-40% of the words
27 that Remington responded with to Gans questions, suspicion and scrutiny are warranted. Here, as
28 described below Conn made way too many errors to possibly correct, although Remington wrote
several dozen pages initially trying to do so.
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1 Simply put, Remington purportedly spoke 2-3 times too fast for her, but she said nothing
2 about that and inferred that she had taken down every single word perfectly.
3 Contemporaneously with that debacle, Remington refused to sign the declaration and then
4 proceeded in good faith to try to fill in the hundreds of.. which occurred plentifully and
5 numerously on every page. When it turned out that there were 10 to 20 major errors with word
6 editions of 10-50 each, on many pages and perhaps most pages, Remington gave up with the
7 corrections and told his attorney that the deposition was entirely useless and would either need to be
8 discarded or retaken. Remington's attorney Harvey Roberts then wrote the formal statutory letter to
9 Gans denying the viability and credibility of the deposition, and demanding or requesting that it be
10 retaken or discarded.
11 Gans refused to do either, apparently got Ms. Conn to acquiesce in that action, and the
12 result was that Gans used said deposition against Remington in the 2016 SOL trial. Conn has now
13 apparently moved to Eureka and presumably has become another "card-carrying" member of Gans
14 enterprise, both in this case and presumably in others since an unethical advocate like Gans can get
15 tremendous mileage out of a badly transcribed deposition, especially if it's done knowingly,
16 willfully, creatively and deliberately. In other words, it's bad enough to not have the answers fully
17 transcribed so that Gans can rewrite them later and recall them however he wants to, however if
18 Conn takes the next step, as was inferred here but not yet proven, and puts in deliberately deceitful,
19 wrong and/or just inferentially inaccurate statements, that goes to a whole other level obviously.
20 Remington made a big deal about this apparent fraud and possible conspiratorial collusion
21 between Gans and Conn in the pretrial hearings, because potentially he has already been and will be
22 further substantially damaged by all of this false, incompetent and incomplete deposition recorded
23 testimony, as has been unethically twisted by Gans so far.
24 Remington requested that Gans and also Conn swear under penalty of perjury as statutorily
25 required under CCP 2025.510-.570, plus federal Rule 30 that Remington's answers were fully and
26 accurately transcribed. Under those above-cited laws, Gans also needs to swear that Remington
27 fully answered all the questions that Gans asked, and that the transcript fully reflects that.
28

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1 Gans was asked at least twice to do that, but ignored that request as too ridiculous to
2 respond to. Therefore subsequently he refused to do anything and Judge Reinholtsen condoned that
3 refusal.
4 Here, a few seconds of looking at that deposition proves that virtually none of Remington's
5 answers were properly or fully transcribed. Remington had a copy of that bad deposition in the
6 2016 trial court room and attempted to show it to Judge Reinholtsen, however he was not interested
7 in even looking at it, and he denied Remington's requests to quash and BAR said deposition as
8 being useless, void and very harmful under the circumstances, which required Remington to argue
9 about the substance and the transcription in open court in front of the jury, causing the appearance
10 that Remington had something to hide here. Nothing was further from the truth, as Remington had
11 explained everything thoroughly, honestly and correctly in the deposition in 2010, whereas the
12 transcript just did not show that, due to all of the...s, which means that Remington's words were
13 spoken, but too fast to be accurately transcribed by Conn.
14 Then, as twisted by Gans in the August 2016 SOL trial, and acquiesced to by the court,
15 Remington did actually have to severely prejudice himself in the eyes of the jury by trying to
16 get the truth out, but having to do it over: 1) all Gans witnesses; 2) a professional stenographer
17 (who probably got the benefit of the doubt from the jury); 3) over the charismatic and believable
18 Gans (who the jury apparently liked and trusted), and 4) the judge, who also seemed exceptionally
19 patient, kind and sympathetic to Remington emotionally, but nevertheless ruled against him on
20 virtually all substantive evidentiary matters and issues.
21 Therefore, Gans proceeded to use said 2010 Remington deposition extensively in front of the
22 jury, and Remington's protestations about it which the judge repeatedly denied, merely prejudiced
23 Remington further in the eyes of the jury as being an ignorant Pro Per22 that was already improperly
24
25
22
During Voir Dire and also during the trial, when several jurors requested to be removed from the jury, it
became painfully apparent that Remington had greatly irritated most of the jurors because of his
26 presentation delays, lack of polished professionalism, possible inferred arrogance, his frequent clashes
with Gans and the court, and mostly because of Remington's delays and apparent inability to deal with
27 Gans prejudicially surprise of Remington with his massive suborning of perjury over the crucial and key
material issue and the entire SOL trial. Plus, at least two present or excused jury members were also very
28 irritated with Remington because they said that they thought he could afford to hire an attorney, and was
just proceeding in Pro Per here to slow this down and "piss-them-off", or for similar bad reasons, which
made them overtly angry, and ultimately cost Remington the trial
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1 delaying the proceedings, which obviously the court did not like either, and also made little attempt
2 to disguise the fact that it did not like Remington, either. As much as anything else, that prejudiced
3 the jury and led to a unanimous negative verdict against Remington shortly thereafter.
4 Remington maintains that at a minimum Gans violated 18 USC 1503 in using that
5 deposition, in violation of CCP 2025.510-.570 and by so doing he obstructed and impeded justice
6 by deliberately and fraudulently employing a knowing bad and worthless deposition in front of a
7 jury, prejudicing Remington further as described above.
8 Overall, after studying the situation rather intently for months, Remington has concluded on
9 balance that Conn and Gans were in some sort of collusive conspiracy to omit certain important or
10 crucial Remington deposition answers, and then leave Remingtons answers open, so to speak,
11 such that Gans could and did formulate his own sworn Remington answer which conformed with
12 his RICO enterprises objectives. Remington and his attorney gave defendants an opportunity to
13 retake the deposition and make it valid and usable, but they refused, liking it just the way it was.
14 Judge Reinholtsen inferentially also joined the conspiracy at this point by ignoring the issue during
15 the August 2016 statute of limitations (SOL) trial, and by also refusing to look at what would have
16 been as bad a transcription as he has ever seen, unquestionably.
17 In conclusion, this is a relevant predicate act that occurred in August 2016 as the court ignored
18 said objections and said that the conventionally sealed transcript in his courtroom was correct,
19 usable and could be used in the SOL trial over Remington's objections. However, Gans knew
20 differently and did noticeably modify his approach after using it and reading about 20 incoherent
21 pages. The pages he read were grossly and improperly transcribed and succeeded in producing
22 meanings approximately opposite to what Remington's actual answers had conveyed, and as
23 explained above. Gans realized that Remington had rather seriously prejudiced himself in his
24 overruled courtroom complaints and objections, in front of the jury, while heatedly contesting the
25 use of said deposition, which the court had inexplicably and prejudicially duly authorized.
26 Apparently, it became evident to the jury that Remington was argumentative and had
27 something to hide by attempting to get some kind of accuracy injustice and of those proceedings,
28

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1 and hence Gans won that battle over that deposition which later led to his winning the war also.
2 S. Paul Dalka. Dalka was a former investigator from the Waterboard and County Health
3 Department, Remington had met several times while he was investigating the Flying J cases, which
4 had contaminated the groundwater under the Burl Tree. In 1999, he strangely briefly investigated
5 Remingtons 832 Westgate property based on some diesel smells which he had noticed while
6 inexplicably standing over on John Mathsons property in 1998 only days or weeks after their
7 project was completed. What he was doing there, talking casually to Mathson apparently, and why
8 he did not notice or stop defendants from dumping 4000 yd. of hazardous debris on both properties
9 as alleged is presently unknown. Instead of investigating and stopping defendants massive criminal
10 dumping conspiracy he decided to ignore the fox and come and investigate the innocent hen.
11 Dalka is arguably the key to this entire case, if he could be traced in detail back to his 1998-
12 2000 activities, which likely is not possible, since he appears to have left the area. Dalka is a big
13 mystery and an enigma.
14 Why was Dalka talking with Mathson on his property in 1998 in the first place during the
15 development of a massive, illegal class one hazardous waste dump? Further, why did he then decide
16 to do such a small, insignificant meaningless and benign test on Remingtons land while he was
17 actually standing on the largest residential hazardous waste dump ever created in County history?
18 Remington had a huge working track-loader parked there on his land which was hand-filled
19 with diesel from a 5-gallon plastic container, and not surprisingly a small amount spilled-out onto
20 the ground which Dalka sampled and later easily determined that a half pint or so of diesel had
21 spilled onto the ground and absorbed to the extreme depths of about 2 inches before it volatilized.
22 Remington now has concluded that more than likely RAO bribed Dalka at that site, and
23 apparently he was responsible for letting that gigantic contaminated illegal project slip through the
24 Countys legal cracks. Remington knows of no other reasonable explanation which would explain
25 why Dalka was snooping around Mathsons property in 1998 but then somehow got involved
26 frivolously on Remingtons land.
27 Dalka always was a rather odd, distasteful, mysterious or slippery character when
28 Remington saw him rather often around the Burl Tree while he was very frequently investigating
the Flying J gas station contamination site; and on balance and after due consideration here,
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1 Remington now sees no other alternative than that Dalka was somehow paid-off to ignore RAOs
2 violations of law. Said violations were apparently blatant, open to public view and must have been
3 known to Dalka, although his visit to Remingtons property did come a couple of months after the
4 claimed dates of the Mathsons-RAO dumping project. Maybe Dalka was just late getting-up there
5 and his intuition led him to believe that something was happening there but he got there two months
6 late. That would also be a plausible alternative since Remington who occupied the next residence
7 150 yards south did not notice Mathsons project at all, but that was because he was not there during
8 daylight ever, was very busy, and he did not have the job of tracking-down contaminated wastes
9 from gas station remediation projects along Broadway in 1998, which job Dalka did have.
10 Dalka appears to have now left the area and may not even be alive. We will soon question
11 Olson, Skillings and Mathson closely about this, but 1998 events are beyond the scope of the civil
12 statute of limitations for this RICO conspiracy, but may still apply to defendants criminal
13 contamination case violations, which were criminal originally, and which are now being
14 conspiratorially covered-up. When US attorneys or other criminal investigatory authorities look at
15 all these facts and criminal violations, it would appear that many of these serious criminal
16 transgressions against public health and welfare may not have statute of limitations, but we will see.
17 The Dalka issue merely infers what we already know: Olson and his criminal operation
18 violated at least 50 known documented hauling, dumping and disposal laws and made big money
19 doing it. Slipping Dalka a couple thousand dollars when the worst contaminated soils were likely
20 already buried in Mathsons draw in sealed 55-gallon drums and covered with clean Cooksey soils,
21 would probably have kept Dalka happy because he never really seemed like a normal, zealous
22 contamination inspector and always seemed rather ODD, circumspect, conceivably looking for
23 mischief for which he could request a bribe, and watchful or guilty as though something else
24 were going-on in his mind that he was concealing. Perhaps coming-over and testing soils on
25 Remingtons land was his way of determining if Remington was feeling guilty, and if so, Remington
26 might have offered him a bribe. That never occurred to Remington, since he was not feeling guilty
27 about anything, but it may have been in Dalkas mind, especially when he decided to unnecessarily
28 test for major soil contamination right underneath a tiny diesel drip from a hand-filled loader tank.

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1 In 1996-2000, Dalka could have made a lot of money with RAO, and you may have ignored
2 all the proper reporting requirements and paperwork documentation with the ongoing Broadway
3 remediations at that time at Gulf Oil, Flying J, Amoco, Sunocco, etc.
4 We are looking for Dalka, but doubt that he will be found alive. Meanwhile we will attempt to
5 determine what he did or knew through the other means listed above. He is more of an older
6 background figure here, than a present active RICO enterprise member who was or is complicit
7 with Gans objectives.
8 T. Mark Hubbard. 100 years from now if there is any hero in these multiple cases, Mr.
9 Hubbard would be a good place to start. He has been alluded to above and he did a contested survey
10 back in March 2008 which Remington permitted inside his fence and Hubbard and Remington
11 although initially having an adversarial relationship, quickly bonded after a few hours on the basis
12 of honesty and reasonable facts and intentions, and before long Hubbard was trying to
13 (unsuccessfully) explain to an ignorant, angry, irrational and combative Mathson, that Remington
14 was actually the good guy here and if this boundary dispute was ever litigated the only people that
15 would ever benefit from it would be the lawyers. Nothing truer has ever been said or written in this
16 lawsuit. Hubbard was the first fully honest, objective and wise witness in these cases, and other
17 than John Aveggio, Harvey Roberts and now inferentially Pulley, he is one of the last of us left here.
18 Hubbard thereafter cooperated with Remington and gave Remington a copy of his valuable
19 survey map and when Gans learned of that, he fired Hubbard immediately, for in essence
20 cooperating with the enemy instead of trying to kill them, and probably there were other factors
21 involved that Remington is not privy to, such as Hubbard was unwilling to go to all-out war against
22 Remington and did not want this dispute to go to trial under any circumstances, knowing that
23 Mathson and Remington would suffer from that and only the lawyers would happily get rich from
24 it.
Today, Hubbard still strongly favors Remington and Remington intends to call him as a wise,
25
honest and ethical witness to testify regarding Gans and Mathsons fraudulent and malevolent
26
intentions towards Remington since 2007, including Hubbards refusal to cooperate with Gans
27
intended frauds and the always required perjury, which Gans demands from any of his witnesses. In
28

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2008, Hubbard tried to mediate these disputes and was in retrospect the only fair, reasonable and/or
1
wise one here then or for several years.
2
Hubbard was here outside of the statute of limitations however he is aware of the foundational
3
frauds and obstruction of justice background and the basic origins of these cases, which defendants
4
succeeded in perpetrating upon Remington throughout this lawsuit. Gans deliberately brought
5 about these cases, apparently for his own financial gain, and perpetuated them by ignoring about 10
6 Remington attempts to settle them, and Hubbard has knowledge of the first several of those.
7 Hubbard caused Remington no damages and in fact arguably saved him considerable money by
8 making it unnecessary for Remington to do a survey with his own money in 2008, which survey
9 Farmers eventually conducted and paid for in 2009, once they had entered the case.
10 U. Three-four (3-4) relevant lower-level environmental sampling and testing
11 technicians, from SHN, the County, Blue Rock and possibly LACO Engineering, as alluded to
12 above.
13 Remington has it on reliable authority that those three or more technicians met, colluded or
14 otherwise communicated socially likely after work, to discuss their different clients, test results,
15 working conditions, workplace environment within their individual organizations, and what each
16 employes opinions were about their own organizations and engineers, etc. It is specifically known
17 through reliable witnesses that Blue Rocks lowest level soil and water testing technician and his
18 boss Ferriman did their best to follow Gans elicit orders to try and destroy: A) the credibility of
19 Remington; B) Maje Hoyos important and influential tests done by their technician; and C) also to
20 attempt to repudiate and discredit the eminent John Aveggios several sets of tests done in 2011.
21 Remington alleges that the Blue Rock, County, SHN and perhaps the LACO Engineering field
22 testing technicians could be considered as directly involved here as lower-level RICO conspirators,
23 intending to, and successfully greatly damaging Remington, as per Gans primary objectives. The
24 SHN technician who worked diligently here at 832 Westgate Drive in late January 2011, whom
25 Remington never saw or met, but who appears in at least 100 Mathson clandestine still
26 photographs, would appear today to not be directly implicated in the RICO conspiracy, however he
27 would have been involved naturally in the chain of relayed information on to his bosses Nelson and
28 Foget, but inferentially without any culpability of wrongdoing. The others wanted to impugn

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1 Aveggios test results and integrity but presumably the other SHN employees did not, at least until
2 gans got to Nelson as described.
3 Detailed discovery is now needed at about this point, however in the middle of all that, clearly
4 Gans managed to reach, influence, intimidate and/or otherwise collude with SHNs CEO Nelson
5 and similarly with the critical Remington environmental expert Foget between 2012-13, which
6 catastrophically led to the removal of Foget from Remingtons case. After Aveggios horrible and
7 untimely death, removing Foget, the last competent environmental expert in the Eureka area, was
8 almost fatal to Remingtons environmental cases, and both Gans and Nelson were counting on that
9 fact. The exact chain of innuendo, slander, bribery, intimidation, extortion and/or conspiratorial
10 collusion still remains to be fully discovered.
11 However, as explained above in some detail, Nelson had no good, or any reasonable explanation,
12 which he could tell Remington on the record anyway, for why he decided to perfunctorily remove
13 Foget from Remingtons case, after Remington had invested at least $40,000 in SHNs litigation
14 services staff. Presumably he had plenty of corrupt and nefarious reasons, however.
15 Equally inexplicable and suspicious is the fact that Nelson easily, without hesitation decided
16 to skip the additional $20-30,000 of Remingtons money, maybe much more, which Foget was
17 scheduled to have earned as Remingtons sole trial testifying environmental expert in these cases.
18 That excellent money for a meager engineer at SHN, which was good for many years to come,
19 would have guaranteed hourly rates for Foget of at least double, if not triple what SHN was
20 normally paying him. The fact that Nelson did not even offer Remington some sort of inadequate
21 full refund even for the money Remington had already paid to SHN, which was fully wasted, infers
22 further that Nelson is justifiably a present, named RICO enterprise defendant, who has been
23 improperly influenced and then controlled by Gans; and, in any event he is now part of the
24 conspiracy to bleed and then crush Remington economically, until he has to give-up this litigation
25 on financial grounds.
26 V. Jason Eads of the law firm of Stokes, Hammer, Kaufman, etc. represents Jeff Nelson of
27 SHN, who badly needs serious federal trial representation now that he has been fully implicated in
28 Gans enterprise.

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1 Nelson had tortiously violated a written contract with Remington, which now appears to have
2 been caused by some of the lower level communication channels alluded to above, all originated by
3 and from Gans acting through Ferriman, Blue Rock Technicians, LACO Engineering, and the
4 County sub- technicians, discussed above.
5 Nelson unceremoniously violated SHNs written contract with Remington to provide him with
6 litigation support through trial, and his removal of Aveggios important replacement Mike Foget,
7 based upon the purported but not believable subjective whim that he doesnt like litigation
8 support, despite Remington having paid them 15-$20,000 in support of that contract, is
9 unacceptable, legally or morally. Remington has thousands of pages of documentary support that
10 SHNs participation in his cases was entirely to support him prior to and during a jury trial.
11 Remington needed environmental expert witnesses for said jury trial and only for a trial! Remington
12 had an investment of about $40,000 in Aveggio alone, to get him to and through a trial, otherwise
13 he wouldve had to pay another $40,000 to get some other witness through said trials.
14 Not only that, Aveggios RAP plan completed in June 2011 was intended for one purpose,
15 which was for him to supervise and undertake a remediation of Remingtons land after a trial and
16 all appeals had been completed. Therefore, when Nelson pulled-the-plug on all of his staff long
17 before we were even close to a trial, but after huge expenses had been incurred, was unjust and
18 unlawful. Very simply put: both Aveggio and Foget were specifically and obviously intended to
19 assist Remington before trial, during any and all trials, after trials in support of appeals, and just as
20 importantly as the preceding, conduct and supervise a remediation and coordination with the county
21 and the Waterboard until the sites were signed off legally. Conversations and plans about final sig-
22 offs and site closure were important from Aveggios first month on the job.
23 Had Nelson properly offered a full refund plus substantial compensation for all of
24 Remingtons lost time, wasted time, grave anxieties and emotional upset due to Nelsons illegal
25 contract breach, then Remington would never have discovered the Gans RICO connection, which
26 has now been proven by knowledgeable witnesses. Treble damages are now sought with regards to
27 any RICO enterprises involvement in removing Foget and sabotaging Remingtons Eureka
28 environmental experts.

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1 Eads will apparently now be representing Nelson, at least until these proceedings reach San
2 Francisco, and how he conducts himself going forward will determine whether he now becomes
3 personally implicated, and whether he falls under Gan influences, charisma and corrupt schemes
4 and objectives, as would be very likely. Gans is quite deceptive and convincing, and nothing excites
5 local Eureka area attorneys more than trying to destroy and arrogant Pro Per litigant and attempt to
6 prove their legal superiority, which for the most part is nonexistent in this remote Northcoast
7 outpost. As above, Nelson is already implicated here, but Eads is not, yet, at least until he starts
8 getting all of his documents, false and fraudulent case facts, and corrupt conspiratorial plans about
9 how best to crush Remington, from the RICO enterprise.
10 W. Harold Hilfiker of Eureka has long been referenced by Gans as a John Mathson
11 sycophant. He appears to have some sort of a use as a witness in all of Gans cases but has not
12 specifically been used yet, nor has his topic of interest or expertise ever been specified. That is how
13 Gans likes to keep it because he can now be like Costa, Mathson or Kishpaugh, it could be used to
14 lie about any fact or issue, as long as it is antithetical to Remington and catches him prejudicially by
15 surprise, before he can locate accurate rebuttal facts.
16 Originally, he is believed to have just been some, misrepresenting and/or lying Agreed fence
17 witness who was scheduled to testify that Remingtons fence was built 3-4 years later than when it
18 really was built, however now Hillfiker seems to have been promoted into having some sort of
19 unknown knowledge about the contamination of Remingtons land although he has never walked it
20 or seen it, nor does he have any real independent knowledge or actual recall of anything there from
21 15-20 years ago, which Gans has not scripted for him.
22 In other words, Hilfiker is believed to have been involved in Mathsons drinking and drug
23 gang since about the 1980s, is believed to be in their personal social circle and apparently has been
24 scheduled by Gans to falsely testify about anything that Gans wants another 2-3 people to back-up.
25 However, what exact topic that will be at this point is presently unknown. Meanwhile, when Gans
26 does eventually and finally give will him a corrupt RICO racketeering assignment, hell figure to
27 swiftly become a full-fledged enterprise member, but today he is only on the fringes with no
28 known, specifically assigned task.

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1 X. Mike Foget of SHN was hired, trained and paid as John Aveggios replacement to act as
2 Remingtons sole independent environmental expert. Foget was very excited at the opportunity on
3 many levels to take over new exciting responsibilities and to further and complete the scientific
4 legacies of his good friend and fellow expert John Aveggio.
5 However, during the Ninth Circuit appeal, Gans got to Nelson with some sort of presently
6 unknown influence, bribes or extortion and succeeded in getting Nelson to remove Foget from
7 Remingtons trial team, crippling Remingtons case instantly and nearly ending it.
8 Remington has many witnesses who have speculated about exactly what happened and when
9 but today it is just conjecture until we get Fogets, Gans and Nelsons, and a few others,
10 depositions and special interrogatories completed. Meanwhile, all we know for sure is that the
11 enterprise improperly influenced Nelson to violate his crucial litigation support contract with
12 Remington so that Gans could destroy Remingtons case on the ground, without ever firing a
13 shot and before the start of any trial. The enterprises strategy failed miserably in that regard,
14 again, and now justice and damages are sought accordingly, against all defendants and law violators
15 associated with Gans.
16 Y. Chris Watt the CEO of LACO engineering has oddly become involved in this case again
17 due to the complex influences and extortions from Gans, mostly allegedly exercised through
18 Ferriman, Gwinn and their testing associates. The exact dynamics among the Eureka environmental
19 testing community, LACO, Nelson and Gans enterprise is not fully understood today.
20 LACO was a valued and trusted environmental engineering resource for Remington in his
21 Flying J case in the mid-1990s and was always timely paid and there never was any friction
22 between Remington and LACO. Remingtons 1990s consultant Gallaty has also died apparently,
23 which is unfortunate, otherwise LACO would have been used again in this case.
24 Recently, however after Aveggios untimely death and also after Nelson had unceremoniously
25 and unlawfully removed Foget from Remingtons case, when Remington contacted LACO with
26 some sort of possible assistance he learned quickly that Gans, Nelson and/or Blue Rock
27 Environmental had all somehow fully discredited Aveggio and Remingtons contamination case,
28 and just as with Foget, persuaded LACO to stay away from these cases and not get involved.

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1 Remington has several witnesses in this area that have told various versions of what happened
2 here, but we now need about two years of careful targeted written discovery and then depositions to
3 determine exactly who did what and when. Gans ruthlessness, desperation, deviousness and
4 excellent sales abilities are already known to be involved, and were intended to advance and/or
5 achieve his highest purpose of eliminating all Remingtons viable experts in this area from his case,
6 and therefore inferentially probably ending Remingtons case altogether. Gans last goal failed
7 miserably because Remington resourcefully went out of the area and found the superlative expert
8 Dr. McEdwards in Laytonville, and had other alternatives down south, as well.
9 Z. Mike Retzloff is merely a residential real estate appraiser which Gans hired to attempt
10 to contradict and counteract Remingtons prominent and preeminent local real estate appraisers and
11 consultants Tidwell, Scolari and Matt Nielsen. Presumably Retzloff has agreed to attempt to dispute
12 Remingtons experts irrefutable conclusions, and then frivolously and probably falsely argue that
13 contaminated property is not ruined, is still valuable and this whole contamination thing is not that
14 big a deal. Retzloff has not made any known appearances or substantive statements in these cases
15 yet, so it is presently unknown whether he is qualified to analyze all the factors involved here and to
16 determine the types and amounts of hazardous materials existing here and their effects on real estate
17 values. Retzloff was originally believed to have been hired to say that Remingtons property was an
18 eyesore and therefore depreciated the value of Mathsons land to the north, but that was before
19 Tidwell proved by survey and related analysis that that theory was unsupportable.
20 Retzloff now may have the role of evaluating the effect on Mathsons and Remingtons land
21 values of both being serious illegal hazardous waste dumps, until they are remediated. What
22 happens after remediation, STIGMA, is also of grave interest and will be explored with him at the
23 proper time. Stigma will also be taken up as a separate lawsuit in about 10 years, perhaps a lot less,
24 when Remington sells the property.
25 Since Retzloff has not done anything definitive or corrupt yet in this case, it is still premature
26 to call him a crook or an enterprise member. He is merely beginning an association with a criminal
27 racketeering Mafia-like chief and presumably has agreed to or WILL sell his soul, swear to any
28 script written for him, as needed or requested for a few hundred dollars of witness fees. ALL Gans
witnesses need to agree to be fully coached as to all aspects of these cases and what their roles
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1 and testimony is required to be; to sign-off-on and agree to any partially or FULLY false
2 declaration which Gans writes for him, in order to deceive or confuse any future court or jury, as
3 needed, of course continue the RICO objectives of crushing Remington financially, emotionally
4 and spiritually. Gans never wants the honest facts, because his defense depends upon falsifications,
5 mischaracterizations, distortions, devices, deceptions and about 50% ordinary lies, hands anyone
6 working with Gans for long must have questionable ethics and a measurable degree.
7 After working with an against Gans for 10-years, all we know for sure is that the truth
8 will beVery frequently departed from in very substantial measure, but whether it will be a
9 federal predicate, imprisonable false corrupt act, or TWO, in Retzloffs case, remains to be seen.
10 Z-1 Gary Evans of Eureka is believed to be another local Mathson drinking buddy and
11 fellow user, who apparently lived somewhere along Westgate Drive at one time, and reportedly
12 watched Remington work with the Mathsons, during the early 2000s, from their hillside chairs,
13 while drinking beer in the evenings, after working at their pulp mill jobs and relaxing, and having
14 fun. Evans was originally supposed to testify regarding when Remington did various
15 developments, including exactly when Remington graded his land and built an agreed fence along
16 the properties approximate boundary lines, as understood by both parties. Now that Remington has
17 produced his accurate, legitimate and very complete daily business records and daily landscape and
18 planting plans, Gans knows that he cannot manipulate days and years anymore, at will, because
19 Remington can prove with actual documentary evidence that everything he swears to his provably
20 true.
21 After the August 2016 trial, the problem with Evans is that he appears to be 110% under John
22 Mathsons and Gans control and influence and is therefore, like most of the others, believed willing
23 to swear to literally anything Gans conjures-up, as long as it is favorable to Mathson, detrimental to
24 Remington and generally mischaracterizes the true facts here.
25 Mathson, Gans and RAO are the bad guys here and Remington is being discriminated against
26 and persecuted because he is the good guy in these actions, who has merely been attempting to
27 stand-up for his God-given, constitutionally bestowed and just California, common-law land rights.
28 Therefore, any collection of good old boys from the local drinking community here, which can
testify to the opposite of that truth, is useful to Gans, because he is adept at influencing juries and
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1 deceiving and conning them with anything which is hopefully detrimental to Remington. NONE of
2 Gans' local gang of witnesses knows Remington at all really and all of their miss conceptions are
3 based solely on the subjective factors that Remington has thick glasses, is serious, extremely hard-
4 working, intellectual and therefore the local lower-class neighbors are mostly just jealous,
5 resentful and generally just dont like him. However, according to BOTH Mathsons depositions
6 they adeptly faked pretending to like him and also pretended to be pseudo-good neighbors,
7 because they never-liked him from the beginning. Gans is excellent with ordinary Eurekans at
8 demeaning and abusing Remington as being somewhat different from the ordinary, beaten-down
9 members of the local Eureka jury pool.
10 Gans and Mathson have about a dozen Evans and Costa/Kishpaugh types willing to go to
11 bat for Mathson, LIE for Gans like good loyal RICO soldiers which they all are, and essentially
12 say or do anything which they are ordered to do or say, as long as it helps their good ol buddy John
13 Mathson.
14 How consistently that batch can now remember and regurgitate their coached lies remains to
15 be seen, especially in view of the fact that they may now be penalized for perjury in the federal
16 system, wherein the state system, and present judges that we have, dont seem to be too worried
17 about it. This RICO lawsuit is among other things a serious bet that Gans cannot and therefore will
18 not keep his flock of perjuring criminal soldiers together through a San Francisco federal trial, and
19 in fact as soon as the going gets tough, they will all desert the battlefield and scatter back into the
20 mountains.
21 Z-2. CONCLUSIONS:
22 1. All for NOW. That appears to be all of the RICO defendants, near defendants, primary
23 associates and other known individuals which we so far know by name, to be investigated further
24 for their complicity and involvement. However, we also know that there will be another 20-40
25 presently unidentified DOE defendants of minor or major importance here, especially coming-out
26 of RAO Corporation one discovery gets serious there, and also from SHN, LACO, Blue Rock and
27 the county testing and administrative bureaucracies, as discussed or inferred above. This document
28 has evolved over about six (6) months now, and as new information, insights or philosophies have
developed here, there have been several changes in the alleged involvement and degree of proven
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1 guilt of several of these individuals named herein, among numerous other evolutions, clarifying
2 and/or additional facts and countless other changes. As explained, this document is merely a first
3 draft and too many changes and differences of perspective occurred over the last six (6) months to
4 get it all exactly consistent in March 2017 with what the facts indicated in September 2016, before
5 Remington and even learned what a RICO enterprise was. It is obvious, that the next rounds of
6 major discovery will cause many more changes to the next draft of this document, as other
7 employees in each organization involved in the enterprise will all have increasingly visible and
8 clearer roles, which may or may not gain them entrance to or relevance within this RICO statement.
9 Today, they are too remote to name, and we decline to presently speculate postulate about them.
10 As discussed above, there are many somewhat peripheral figures that have not been fully
11 indoctrinated yet by Gans mostly because they have not testified at any trial yet. Schwartz, Hillyard
12 Gwinn and Ferriman are four (4) such witnesses who are RICO associates, among MANY, but who
13 are not named as defendants yet, because they have not yet committed any Gans subordinated
14 perjury which will now need to be repeated in the federal case, or any other known federal crimes
15 in most cases. So, we must give Gans and them a little bit of time. For example, who can doubt that
16 Randall for example will not be a RICO defendant in the next amended complaint?
17 However, after the first significant round of written discovery, where perjurious statements
18 will be sought and undoubtably rather easily procured under oath, in order to be consistent with
19 their state falsifications and perjury in the 6-7 cases cited above, once Gans barrage of frivolous
20 objections are countered and said witnesses are compelled to respond to the substance of the
21 questions, then it would not be unlikely and it would be expected that we will add another 10 or so
22 named RICO defendants herein, certainly by the time of the next trial, wherever that may be. All
23 that last overly complex, abstract, unwieldy but grammatically correct sentence means is that after
24 minimal federal discovery there will be a lot more RICO defendants, without a doubt.
25 2. A contract on Remington? Another contingency which Remington has alluded to
26 before, but which is understandably significant and close to his heart is that this RICO enterprise
27 may well attempt to do away with Remington somehow, or alternatively may be Remington will
28 just somehow otherwise wind-up mysteriously dead of natural or other unknown but suspicious
causes. Hopefully that wont occur, but if it does it will probably be adequately recorded,
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1 anticipated or pretty obvious who did what when and how, and the reason this issue is somewhat
2 emphasized is because all of the present RICO enterprise defendants, such as the Mitchell firm
3 attorneys for example, like say Plotz, should have just about as strong a motivation as Remington
4 does to prevent Remington from having any accidents by Mathson, Skillings or Kishpaugh, for
5 example. The reason for that is been explained, and will not be done so again here, but if anyone
6 does not yet know or recall the legal reason for that, then they need to Google some RICO cases
7 and law to see what can happen to an entire RICO enterprise, when a major crime is committed
8 which is linkable to one of the prominent members. Yes, even some of the more supposedly
9 innocent subordinate members such as say McBride, Joy Mathson, Kloeppel and even Ferriman
10 or Hillyard, may wake up in the middle of a hornets nest if Skillings, Olson or several of the
11 other chief suspects mentioned above decide that theyre smart enough to go violent without
12 ever being suspected or getting caught, and therefore they decide to bypass all this legal crap and,
13 like Trump, perhaps, just put a stop to all this, for good.
14 3. Gans vast resources of lying witnesses have the capability and intent of framing
15 Remington. What additionally concerns Remington in this paragraph is that were Remington to
16 strangely die prematurely of natural or violent causes, Gans has the supreme capability of easily
17 bringing-in 5-6 impressive, credible-appearing witnesses, all of whom will have been named herein,
18 to swear that they saw and heard Remington arguing, and then brandishing a weapon where he had
19 to be killed in self-defense, and where at least one of them will have seen the whole thing very
20 close up. Predictably, only one will actually see the act because no two of them could ever
21 coordinate their false stories for very long. Therefore in the more likely scenario the other 4-5
22 lying Gans witnesses would just swear that they absolutely saw Remington was there, saw his
23 drawn and pointed gun, heard his unmistakable voice, would never forget his Coke bottle
24 glasses glinting in the surveillance spotlights, knows his car well, etc. Gans could also frame
25 Remington in an infinite number of ways with similar lying witnesses, wherein perhaps they saw
26 Remington kill someone (which someone was either killed by someone they hired or killed by one
27 of themselves) in cold blood, which would presumably warrant the death penalty for Remington.
28 Wouldnt that be an easy way out of this for Gans and his RICO enterprise? In either alternative,
Remington will be gone as an adversary here, or in prison forever, either of which works for Gans.
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1 In that case, some of Gans problems on the contamination side would be solved, however
2 the problems for everyone else named in this statement would have just begun.
3 4. Other criminals not yet named here. Potentially, all secretaries, assistants and close
4 associates of any of the named or almost named defendants herein, may will now be a criminal
5 racketeering member deserving of prison. We just need to develop the data further through
6 extensive discovery, connect all the links and then form the fair and reasonable inferences.
7 Julie McBride is an example of a named active and significant RICO enterprise member, but
8 someone whos real corrupt role in sinister significance was not realized until at least four months
9 into this investigation. She is already guilty of complicity in, authorship, involvement with Gans
10 fraud and deceptive devices, for many years, and also being an accessory to multiple mail and wire
11 fraud transgressions, among many other things, and has been reliably fingered here because of the
12 longtime involvement she has had with Remington directly. Additionally, she is a pretty good
13 example here because Remington has analyzed what she has done, what she knows and the clear
14 criminality that she has condoned, eagerly and enthusiastically participated in and help to plan. In
15 her case, given her position, and longtime extreme closeness to Gans, and what she has word-
16 processed and researched for him over many years, it has become obvious that it is not a question
17 of what she should have known, but a question of given what she obviously does know of Gans
18 criminal activities, what should she have done about it? What should she do about it now?
19 McBride gets all of Gans perjuring witnesses on the phone to set-up their coaching sessions,
20 probably hears significant parts of most of the calls, types-up scores of pages of illicit notes, and
21 certainly understands all details of these cases and what the witnesses are being asked to testify
22 and/or lie about. McBride knows as well as Gans what needs to be proven, what grave weaknesses
23 exist in Gans evidence (for example how Skillings was destroyed in pre-trial hearings with the
24 2003 photographs), and what Gans could possibly do to remedy those deficiencies. That is because
25 by necessity he confides in her, she advises and edits all of his thoughts and actions, whether
26 written or oral, and since he is an intelligent researcher and executive assistant in all likelihood she
27 is smarter than Gans on most things, and entirely competent to figure all this stuff out for herself.
28 She knows as well as Gans what soldiers they have at their instant command to accomplish
any crime or to swear to any lie, just as well or better than Gans does himself. For any Next
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1 Generation or Voyager Star Trek aficionados, it is not inconceivable that Ms. McBride is the
2 BORG queen of this enterprise and pushes Gans into these corrupt acts which are all automatically
3 paid for rubber-stamped by Lawrence of Allied. Just as likely, Lawrence is the TRUE all-powerful
4 BORG queen here, continuously in touch with her RICO collective, and in any event it will
5 take a few years to positively develop all that information, however we will eventually do so, and it
6 will be satisfying and enjoying to do so. In any case, neither McBride nor Lawrence are little,
7 young, naive clerk typists barely able to spell, and potentially either one could be the true BIG
8 BOSS and demonic brains behind Gans. Then there is Joy Mathson who could be described
9 similarly to the above women, and since she was one of the original primary instigators of these
10 disputes, it would be only just if she now commits multiple federal predicate acts as she brilliantly
11 attempts to save John and herself, with more of the treachery that she was ready to perpetrate on
12 Remington and the court in August 2016. We will soon see if shes smart enough now to avoid
13 federal charges with the penalty of possible incarceration.
14 Similarly, we will be looking at Lawrence, Olson, Kluck, Nelson and several others with
15 respect to the culpability of their assistance, and whether they are guilty of anything, or whether
16 they are just normal air-head employees, merely doing their jobs and are actually in fact oblivious
17 of the crimes, ethical transgressions or the possible illegal acts being considered by or committed by
18 their bosses.
19 5. All of the herein named RICO defendants, near defendants and Associates do other
20 honest work, even Gans, believe it or not.
21 That fact complicates the analysis somewhat, blurs the culpability slightly and will be most
22 enterprise members main excuse or alibi. The higher you get in the Enterprises hierarchy, the more
23 time they spend on the Enterprises anti-Remington goals and objectives. Conversely, the lower you
24 go on the Enterprises organizational charts, you quickly encounter enterprise associates who spend
25 less than 1/1000th of their time trying to illicitly defeat Remington in these litigations.
26 There are also many members and associates named herein including without limitation:
27 Costa, Jon and Mickee Kishpaugh, John and Joy Mathson, Evans, and others, which dont have any
28 regular employment and live-off various types of government programs and benefits, supplemented

304
1 by other largely illicit money-making activities, not the least of which is testifying falsely for Gans,
2 and against Remington, at high hourly rates, in as many forums as possible.
3 Skillings is believed to be the worst apple of all here and he does appear to still have a
4 part-time job or some role with RAO, at least until recently. However, although Skillings is the
5 most obvious RICO criminal assassin here, there are at least 2-3 others which Remington has also
6 come to fear over the last 4-6 months, because they may not be quite as obvious or overtly hostile
7 and violent. In August 2016, he did appear to be ailing somewhat and complaining of some type of
8 equipment-operating based disability. Although we just dont know yet, he is believed to be likely
9 on some kind of full disability by now which probably does not prevent him from drag-racing,
10 bullying and beating-up people, and otherwise conducting a very normal and physically vigorous
11 life. Even if fully wheelchair-bound, he could clearly kill a man physically, with his bare hands with
12 no trouble, and probably with very little regret remorse, either.
13 4. List the alleged victims and state how each victim allegedly was injured.
14 Bruce Remington, in Pro Per, who is the writer of this document was the primary individual
15 harmed here, but it was his land, timber, gardens, fences, inventory, property and interstate business
16 called the Burl Tree which comprised of the badly damaged BUSINESS items and property, and/or
17 victim. Additionally, Bruce Remingtons wife Suzanne is also a joint owner of the Burl Tree and
18 Westgate property, so she has also been substantially damaged, as have their daughter Laurel and
19 her grandchildren, to a lesser degree. Other relatives, siblings and possible errors have also been
20 slightly affected to a presently unknown degree.
21 There are many other independent and unrelated victims here, especially affected by the
22 environmental claims, however, WHO live up-wind from the dump were the lethal 60% chrysotile
23 microscopic fibers freely below, and there are numerous downstream and other lower property
24 owners, most notably the Eggerts and their major timber property which like the Burl Tree is an
25 income producing business. All fishermen, consumers of any shellfish or users of elk River and
26 Humboldt Bay have also been damaged and poisoned by the various toxins emanating from
27 defendants don't as described herein.
28 Examples of the local neighbors damaged are the several (extended) Wilber family members
to the east of Remingtons property, the Larry and Larry family directly across the street, the
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1 Kishpaughs and many others that live directly across the street from, and essentially East from
2 Mathsons dumps that affect several acres of Remington and Mathsons land total. Some of those
3 will be determined in the future as time permits, whether local inhabitants in this neighborhood can
4 be surveyed for known physical inhalation or other possible injuries derived from Mathsons
5 hazardous waste dump.
6 Many of the environmental damages to all nearby wildlife, plants, animals, amphibians,
7 waters and the purity of all adjacent land and water in the health and vitality of all nearby living
8 people, animals, fish, plants and amphibians were caused by the toxicity and contamination of
9 defendant's dump. Requested compensation for the numerous environmental causes of actions and
10 damages cited herein in this complaint and in the state complaints are explained below under relief
11 requested primarily.
12 This RICO statement and cause of action under 1961-2 is not for personal injuries to
13 Remington but are solely for injury to his property and the Burl Tree business as described herein.
14 These damages include:
15 (1) Damage to the land itself at 832 Westgate Dr. itself from defendants original 1998
16 contamination and the continuing nuisance and trespassory damages which have continued since
17 then, all of which now require remediation. These damages are described with extreme particularity
18 in the environmental portion of this complaint plus the several associated state complaints and filed
19 documents, all of which relevant ladder documents are included herein by reference;
20 (2) Significant damages to all related and adjacent property, including Remington's redwoods and
21 all his adjacent gardens, springs and watercourses, plus damages to the numerous other upwind and/or
22 downstream or other adjacent property owners, detrimental inhalation and related deleterious health
23 effects in the adjacent neighborhoods, due to the wind and extensive harmful downstream waterborne
24 effects, extending all the way to the Pacific Ocean, described above. The owners of the large Eggert
25 property to the south have been especially damaged;
26 (3) Extensive damage to the Burl Trees diverse property described herein, in all of the ways
27 mentioned. The Burl Tree owns all of the land, inventory, related development, the structures and
28 all of the massive gardens and plant life. All of it has been damaged, and the entire property is now
un-repaired, unsalable, unfinished, and most of it is not even finishable because all of Remington's
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1 time is spent on these litigations. It is believed that Remington's necessary defenses to Gans
2 enterprises frivolous lawsuits, allegations and future malicious prosecutions; vexatious litigant
3 allegations, etc. are valid damages here to be recovered from this RICO enterprise. Remington
4 himself is not a professional attorney, so his time spent prosecuting his contamination and RICO
5 enterprise allegations may not be fully recoverable, however some of his efforts as a paralegal or
6 secretary, and the ordinary expenses those tasks generate, ARE believed to be recoverable in some
7 measure. Remington expects to have actual attorneys involved here and hence expects to incur real
8 attorney fees in due course, and at that time he will add them specifically to these damages, and
9 relief requested.
10 The successful extortion of Remingtons three young granddaughters, wife and 45-year-old
11 daughter have been discussed herein. Gans and Mathson, et al have fully succeeded in blowing all
12 of them away, which emotional, psychological and/or punitive damages will be requested in the
13 environmental portion of these lawsuits, but not as a RICO treble damage, because they do not
14 directly relate to Burl Tree business losses. However, overall they are relevant to mention because
15 said extortion of infant, pre-school to about second grade girls, demonstrates the intentional
16 ruthlessness, determined, dogged pursuit of their RICO objectives, no matter who is hurt or killed
17 in the process, and the increasing total desperation of Gans and his soldiers. Out of the originally
18 six (6) most directly involved and affected individual owners, direct heirs and users of this Burl
19 Tree property, five have been now successfully extorted by defendants and only one remains
20 steadfast, which is Bruce Remington.
21 5. (a) Describe in detail the pattern of racketeering activity alleged for each
22 RICO claim. A description of the pattern of racketeering activity shall include the following
23 information, (a)-(d), as explained in great detail below: The alleged predicate acts and specific
24 statutes violated; the dates of the predicate acts, the participants in them, plus a description of
25 the facts surrounding each predicate act; where fraud is alleged extreme detail and
26 particularity is required; and, describe whether the alleged predicate acts relate to a common
27 plan or objective of the enterprise, and if so describe that in detail. The charts and some of the
28 other materials referenced below are included here and also now in separate Volume III.
A. INTRODUCTION.
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1 Remington herein alleges that at least 17 generalized categories of federal predicate acts were,
2 have been and continue to be violated here today by Gans enterprise with multiple violations of
3 most of those laws as indicated.
4 Unless one is the Central and long-time target of a RICO racket and pattern, such as
5 Remington has been and still is here, a RICO racketeering enterprise is somewhat abstract,
6 ambivalent and complex to describe clearly. Until a street gang or actual criminal mafia family
7 actually attacks you, damages your property and severely frightens you and your family all of this is
8 kind of artificial and perhaps seems more like some sort of a TV drama, than reality. However, after
9 you live that reality for several years, feel the fear and repair the damages, at some point this
10 RICO extortive racket concept, has become the most accurate legal manner of describing these
11 events going on here today, even as this is written.
12 Remington will continue his feeble attempts to describe all this with specificity, however, with
13 as few words as possible plus charts, tables, generalizations and many detailed, specific times,
14 places, persons and act explanations, at the risk of over-explaining this, as opposed to the worse
15 alternative of not providing enough specificity. As has been made clear by now, Remington has
16 already discovered and realized sufficient details to begin this RICO case process, but when real
17 discovery starts against these numerous defendants, we expect to improve the significant material
18 facts by 5-10 fold. In fact, of the 30-40 most important defendants or possible future defendants
19 named herein, we have actually only received prior discovery on one of those 30, say, which would
20 be John Mathson. Additionally, we have dozens of instances of federal mail and wire fraud against
21 Gans and Plotz, but almost nothing on anyone else. Therefore, it could easily be said without
22 exaggeration that we have only gathered 5-10% of the expected and anticipated material RICO case
23 documents, and have actual oral depositions and/or prior sworn trial testimony again affecting no
24 more than 5% of what is known to be out there, and now is in the process of being sought.
25 Therefore, if this court decides that it wants to truly understand this enterprise and eventually
26 to reasonably ascribe to and accept this criminal Gans-led racket as fact, then eventually MUCH
27 more detail will be required, which will require numerous major discovery battles because Gans
28 and his corrupt Associates specialize above all in technical administrative obstruction of discovery

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1 processes, under the meticulous details of the California Code of Civil Procedure, both state and
2 federal.
3 Remington will attempt to reduce and moderate these anticipated discovery wars, protective
4 order motions, hundreds of pages of boilerplate frivolous objections from Gans, et al, and the
5 obvious numerous motions to compel discovery responses which will soon all be required and
6 ongoing herein. However, Remington and Gans do not get along about anything regarding
7 discovery whether its the permitted topics, or the location and time of depositions. All of this will
8 be very time-consuming, because Remington does not write short, succinct, conclusively incisive
9 phrases, very definitively or well, but will attempt to modify and abbreviate his writing styles so
10 that discovery disputes and hearings can be conducted over only a few years instead of over many.
11 1. Table 1, which follows, in two pages, is the short and concise list of 18 USC 1961 RICO
12 predicate acts violations listed in succinct form;
13 2. After that, the "predicate acts diagram" summarizes the criminal predicate acts in a geometric
14 pattern emanating from the Gans/Lawrence/RAO and Mathson leaders outwards, with all damage
15 intended specifically for and occurring to Remington and his businesses land and property, as
16 shown23.Remington has several geometrical variations on this at all of these charts and may or may
17 not attach more than one with this document, and in Volume III;
18 3. Next, is an organizational chart depicting the authority and power structure is presently
19 reflected by these predicate acts of the last four years;
20 4. Following that and as a specific response to 5 (a) on the form entitled "RICO CASE
21 STATEMENT STANDING ORDER" is Remington's November, 2016, 26-page document
22 entitled "Remington's RICO statement and explanation of Gans racketeering enterprise, which is a
23 generalized statement of federal violations, who did the violating but not listed specifically or in
24 any chronological order;
25 23
Recall that "The Burl Tree" is Remington's long-time all-purpose Burlwood products business
established in about 1971, and located today at 832 Westgate Drive. The Burl Tree owns the land and
26 gardens here, most of the house and contents, and the entire inventory inside and out was everything of
value that is not been yet damaged in these cases. Detailed damages to Remington's property and business
27 are detailed far below at the RICO statements #15-16.
28

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1 5. Also as part of this introduction, Remington will preliminarily describe the general
2 nature of Gans racketeering enterprise, including without limitation: its structure,
3 characteristics, purpose, specific schemes practiced in pursuit of its purposes; the relationships
4 between the enterprise members, the longevity of the enterprise, in its present form visible today,
5 and its loose hierarchical structure. In the next section below, we will especially focus on Gans
6 generalized schemes which employ false logic and illegitimate deceptive devices against
7 Remington in all these cases which criminal evolution has been closely observed and carefully
8 studied by Remington since at least 2007. Those specific and corrupt Gans schemes, as discussed
9 above, basically had the simple purposes of: saving the overall enterprise money; making all
10 members of the enterprise as much money as possible; crushing and punishing Remington in every
11 possible way described below; and avoiding all possible cleanups on both sites while attempting to
12 keep all enterprise members out of prison.
13 6. Finally in this section is a much longer prepared document entitled: "Chronological
14 Pattern of Predicate Acts from 2012-2016, and some relevant background. This is (or WAS) a
15 101-page, initially stand-alone document also prepared separately in late November 2016 in
16 specific response to 5 (b), and therefore has some redundancy, inevitable overlaps with some of the
17 other discussions written a month later, or a month earlier, and also is somewhat obsolete,
18 especially where it may conflict with any of the specific statements in any of the other volumes
19 herein, or even with the last hundred or more pages of this document, which were all written at least
20 2-3 months after said above hundred and one page document. Many facts and perspectives by
21 Remington about this RICO enterprise did substantially change as defendants corrupt and criminal
22 activities became better understood, as they were recalled each and every day for months, and as
23 more precise detail was gathered and recorded, by studying contemporary notes and documents.
24 7. Table 1 next follows below, and is the short and concise list of the general types of 18 USC
25 1961 RICO predicate acts violations alleged herein, listed in succinct form:
26 Table 1: Predicate Acts used in 2016 RICO Cause of Action
27 1. 18 USC 1951, Hobbs Act. EXTORTION, deliberately causing FEAR in Remington;
28 2. 18 USC 201. BRIBERY, at least a dozen incidents of varying severity are alleged;
3. 18 USC 1341. Mail Fraud (overlaps with California B & PC 17, 200, et seq);
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1 4. 18 USC 1343. Wire Fraud, including internet, email and phone;
2 5. 18 USC 1503. Obstruction of Justice. Gans has no honest scruples or ethics;
3 6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor;
4 7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite;
5 8. 18 USC 1513. Retaliation Against Witness;
6 9. 18 USC 1515 (a) (1,3 & 6) and (b),all definitions apply, such as Making false statements,
7 omitting information, intentionally concealing facts and destroying material evidence.
8 18 USC 1952. Barring interstate travel with racketeering or gambling income;
9 10. 18 USC 1956. Money laundering uses by RICO enterprise defendants are illegal;
10 11. 18 USC 1957. Specifically bars property purchases with laundered dirty money;
11 12. 18 USC 1961-4, et seq. Money laundering statute bars use of illegal profits;
12 13. 49 USC 5101, et seq, Improper safety permitting for hauling hazardous wastes;
13 14. 15 USC 2607, 2614-15 and 2642. Violations of hazardous materials hauling laws;
14 15. 42 USC 1983, Actionable deprivations of Remingtons rights by defendants.
15 16. 42 USC 102, Selling, using and dealing in various controlled substances;
16
17 B. "Pattern of Racketeering Activity". Before we specifically address the specific acts, violated
18 federal statutes, individual violators and when those violations occurred, we think it is useful and
19 vital to first analyze and understand: What Gans Enterprises objectives were and still are;
20 What the structure and characteristics of a RICO enterprise actually looks like; and what a "pattern
21 of racketeering activity" really means with respect to its purposes, relationships, longevity and
22 hierarchical command structure.
23 1. What are the overall purposes and objectives of Gans RICO racketeering enterprise?
24 In essence, why was it created in the first place and why wouldn't the ordinary conventional,
25 ethical and legal process have worked here for Gans objectives and goals? Gans PURPOSES:
26 a. Save money for the insurers, RAO and Mathson by Avoiding all cleanup costs here on both
27 properties forever, or until Remington dies;
28 b. Get all of Remington's land free, including the substantial portion they have trespassed

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1 upon, and also importantly pay no rent either for their 18-years, and counting, of occupancy or going
2 forward for any of Remington's substantial amount of land that defendants are heavily using and
3 abusing.
4 c. Make money for Gans, Allied, RAO and Mathson, plus Maximize all enterprise members
5 wealth, income and happiness, starting with Gans, of course and the $300,000+ he has made so
6 far to date from these cases, and then the highly paid Lawrence, on down to their numerous experts,
7 clerical workers and lying percipient witnesses, all of whom are happy, well-fed, care-free and
8 making much more money here than they normally would in their regular lives;
9 d. CRUSH Remington financially, emotionally and intellectually by forcing him to pay all
10 expenses in these never-ending litigations including cleanup costs all expert costs from both sides
11 and all defendants costs and attorney fees by means of obstructing justice, bribery as needed,
12 intimidating and extorting as many witnesses as required, under color of law since Gans still
13 remains legitimate and licensed California attorney;
14 e. Cover-up and minimize all the crimes by all defendants here since 1998 in order to STAY
15 OUT OF PRISON, and enact or put into effect a. above. Total cleanup costs here on both properties
16 would be over $500,000, which defendants have refused to pay, and in order to avoid that, and to
17 avoid carrying- out their legal responsibility to clean up the mess that they made here, defendants
18 have been willing to violate any and all laws as needed especially beginning in the 2012-16 period,
19 when this RICO enterprise was created. This cover-up by defendants has become entirely corrupt
20 since they have had to spoil evidence by removing all visible debris, they have understated all
21 significant parameters of volume and toxicity regarding their dumped debris, and they have had to
22 bribe and/or extort numerous experts and percipient witnesses, with no end in sight;
23 f. Punish Remington beyond mere monetary and emotional destitution and bankruptcy.
24 Gans Enterprises final crucial objective is to further punish, torment and damage Remington
25 completely, by whatever methods it takes, including:
26 (1) Subjecting Remington to this unpleasant and costly never-ending litigation with endless motions
27 witness costs, until he goes into bankruptcy, and continuously harass him as recently, with nothing
28 but disingenuous lies, false motions in limine, overly simplistic and bad special jury instructions,
and solid mischaracterizations, to oppose;
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1 (2) Kill him if possible by literally physically poisoning him, making his skin cancer worse by
2 wearing him down mentally and physically until he dies of stress or old age;
3 (3) Break his spirit psychologically with improperly influenced, unjust judicial decisions,
4 continuous vandalism and never-ending property damage;
5 (4) Cause him endless worry and fear from extortion by all of the attorneys involved here, public
6 pressure from governmental agencies and the public in the neighborhood, by simple coercion,
7 intimidation, plus the unpleasant constant early morning motion activity, which as Gans is well-
8 aware of is unnatural for his biological clock;
9 (5) Generally, by means of the above and all the other factors not mentioned here, Gans seeks to
10 punish Remington indefinitely, destroy him financially and into the grave for his generally
11 arrogant attitude towards Gans and the trailer trash neighbors, and for Remington's clear and
12 longtime recognition of Gans corrupt, unethical and criminal activities in defending these cases,
13 and for Remington's great audacity in standing-up for justice against Gans for 10-years now.
14 Therefore, in retaliation and for Gans perceived retribution, Gans now seeks to cause
15 Remington further extreme emotional distress, and then finally to sue Remington for Gans long-
16 time stated goal and intent of recovering punitive damages and malicious prosecution damages
17 from Remington, to fulfill the Enterprises ultimate objective of suing Remington for some sort of a
18 multi-million-dollar verdict after all the contamination cases are over, and after the enterprises
19 anticipated intermediate victories.
20 2. What are Gans Enterprises multifaceted specific schemes to defraud Remington and
21 conclusively WIN all these cases, ruin him in the process and achieve all of the objectives and
22 related detailed purposes named in section #1, immediately above? In no particular order of
23 priority, Gans for years has been observed to be actually and successfully managing and
24 ordering his experts and soldiers to do the following unethical and corrupt activities in these
25 lawsuits:
26 a. Gans has ordered John Mathson to conceal the evidence of all his dumped debris on Remingtons
27 property by means of removal by hand, burial with weeds and redwood needles and in some cases
28 reduction in size by sledgehammer and then hand removal. All that is criminal evidence spoliation,
analogous to OJs hosing-down the Bundy crime scene to remove all blood evidence, because here
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1 Mathsons hazardous debris goes 10 to 20 feet deep, and cosmetic cleanup of the surface and broom
2 sweeping it accomplishes very little;
3 b. In support of the above evidence removal, as new asbestos pipes, lead, asphalt and miscellaneous
4 hazardous debris becomes exposed each month from water and wind erosion, Gans has ordered
5 Mathson to remove and conceal it also, so that the sites look cleaner when experts or regulatory
6 authorities visit. Said removal by Mathson violates 15 USC 2607-2642 concerning numerous
7 hauling violations of the asbestos and related hazardous wastes without proper permits;
8 c. Fraudulently misrepresent all technical, testing and mathematical evidence, especially any
9 volume and toxicity evidence which relates to the overall magnitude of the contamination here as
10 opposed to its insignificance and/or minimalist nature as Ganz scheme dictates;
11 d. Obstruct justice in any and all court proceedings, including trials and motion hearings; bribe any
12 and all witnesses and participants as necessary, including court personnel were useful and in this
13 case one trial judge if required;
14 e. Make Remington physically ill, gravely ill if possible, by stirring-up and exposing him to
15 microscopic, invisible asbestos particles and Chrysotile to the air, plus ensure that there is always a
16 constant volume of insidious and infectious bacteria oozing down from Mathsons unpermitted
17 septic systems and/or otherwise contaminating and infecting Remingtons water supplies below,
18 which in the past have sent Remington to the hospital, and two additional times made them gravely
19 ill for at least one month, etc.;
20 f. Extort Remington to break his will, make him afraid and unable to work effectively whenever
21 possible by verbal and whatever other means arise under the circumstances. Gans himself has been
22 effective at that, so has Plotz and Kluck and of course especially John Mathson as he still, even in
23 2017, almost daily circles Remingtons land, studies the security fences for weaknesses and
24 evidence of attempted animal incursions, tampers with this fences and gates (daily on March 6-8
25 2017 and glowers and/or yells at Remington, if he is around in daylight or darkness, and not only
26 writing these documents.
27 g. Gradually weaken Remington financially with unending litigation, numerous experts to refute,
28 hundreds of motions to respond to mostly requesting sanctions, however defendants have not

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1 received any sanctions against Remington in many years and are about zero for their last 50
2 requests.
3 h. Further damage, distract, anger and overall extort, coerce and force Remington to give-up his
4 attempts to ultimately achieve justice here, (which justice would be defendants paying for the
5 cleaning-up overall of Mathsons contamination), by Gans primary means and devices of: 1)
6 continuous vandalisms caused by his soldiers: Mathson, Kishpaugh and Skillings, et al; 2) by
7 cutting his fences to allow dear and people to steal his inventory and destroy his best and weakest
8 plants; 3) of taking continuous photos of Remington, all day every day while he is working, with a
9 powerful flash camera which in the redwood forest twilight, simulates gunshots; 4) by sabotaging
10 his irrigation systems and puncturing his water tanks, etc.
11 The clear objectives of this type of Gans scheme is to distract, anger, demoralize, weaken and
12 take all of Remingtons available (or unavailable) physical energy, time, costs in hiring dogs to
13 secure his property, with the inferential ultimate Gans objective with this type of criminal behavior
14 of angering Remington sufficient for him to retaliate with some sort of a criminal response of his
15 own such as arson or physical attacks on the Mathsons or their animals or property, or possibly to
16 kill some of the animals that Mathson leads into Remingtons fenced enclosures, presumably to
17 tempt Remington to kill or injure them, which would also be in violation of law and make
18 Remington the criminal here rather than Gans and Mathson, et al.;
19 i. Bribe essentially all of their (Defendants) witnesses plus at least one Superior Court file clerk, at
20 least one judge, and at least one environmental engineering consulting firm which just happened to
21 employ Remingtons crucial environmental expert engineering witnesses;
22 j. Collude and conspire with the interstate members of their financing insurance companies, keep
23 giving them false hope and encouragement that these cases would soon be over, In order to ensure
24 that Gans enterprise kept receiving unlimited funds and maintaining their overwhelming legal
25 advantage against Remington, mostly employing mail and wire fraud to accomplish that;
26 k. Meanwhile all enterprise members, especially Gans and his legal partners, Mathson and, RAO
27 and all of their expert witnesses, kept improving their finances, largely by means of illegal money-
28 laundering based on their illegal activities for many years, so that they could maintain their war of
attrition against Remington indefinitely;
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1 l. Tampering with Remingtons few and crucial expert witnesses, including: Tidwell (bribery,
2 intimidation and improper influence exerted by Gans in offering Tidwell future work for many
3 years in exchange for his not fully backing the pro per Remington here, in a one time lawsuit);
4 Figas (intimidation, extortion, blackmail, coercion, etc.); as to Figas, Gans ordered extortion
5 involved the threat to do bodily or physical harm to Figas himself and/or his property including an
6 excavator and trucks, plus the threat of exposing Figas to other types of investigations; Bianca
7 (Who does business with many of these defendants, who have now strongly suggested to him that it
8 would be better for him to discontinue being a witness for Remington than to continue as during
9 2016. That is the typical Gans and RAO operating method of making Remingtons witnesses or
10 himself, An offer that they cannot refuse, or at least would be real damn stupid if they did.
11 m. Damaging and hopefully destroying the entire Burl Trees business by complaining of, without
12 limitation: Remingtons chain sawing of burl; chain sawing of redwood rounds; chain sawing of
13 redwood and alder trees or actually just turning on a gasoline chainsaw; Remingtons lawful Burl
14 storage and perceived zoning violations; and, by preventing Figas from hauling iron to Oregon and
15 California markets; by preventing Figas, Jagger and their numerous international wholesale buyers
16 from Colorado to the Philippines from visiting and taking the time with Remington as needed to
17 consummate several hundred thousand dollars worth of burl wholesale deals, ETC, as additionally
18 enumerated herein;
19 n. Blocked several possible real estate property sales from prospective buyers of the 832 Westgate
20 property, for which Remington receives several serious quarries per year. However sale of the
21 property is not presently possible due to its contaminated, uncertain and nearly worthless value on
22 the real estate market today, since no licensed real estate broker could risk the liability of selling it;
23 o. Defendants 42 USC 1983 civil rights violations continue with their frequent and almost
24 continuous complaints to the County Health and Building departments, to the courts, to the
25 Department of Public Works, to Judge Reinholtsen and all neighbors along Westgate that have the
26 time to stop and talk to the Massons as they walk their dogs, etc.
27 3. What type of enterprise has Gans developed and maintained at such a high level here?
28 Gans Eureka-centered RICO racketeering enterprise includes all of the individuals, corporations,

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1 corporate officers, partnerships and unaffiliated other types of individual witnesses which Gans has
2 found helpful to advance his objectives.
3 Under 18 USC 1961 (4), this type of Gans enterprise is defined as an enterprise
4 associated in fact which comprises any group of individuals, with a common collusive and
5 racketeering purpose as alleged herein in detail, although not in any specific legal entity. As further
6 explained herein, Gans enterprise never has any meetings where everyone attends; and, is just an
7 informal association of specialists, which never meet as a group but assist only Gans, their eminent
8 Godfather-type leader when he summons them to do a "job" for him, as needed to assist him, and
9 the enterprise in reaching his very specific overall objectives and schemes, as just outlined above.
10 Gans himself defines all RICO enterprise objectives and schemes and then requests that the
11 individual salaried members assist him in their specialty tasks as required, and as originally
12 arranged, agreed and/or contracted for.
13 4. A RICO racketeering enterprise, in addition to having specific purposes and schemes as
14 outlined above, needs to have understandable structural features which include, without
15 limitation:
16 A. Relationships among the RICO members;
17 B. Continuity, related to the purposes of the enterprise which to in fact be a true RICO
18 enterprise needs to show evidence of past, continuing and likely future criminal activity;
19 C. Longevity, of at least two or more years; and
20 D. Some form of hierarchical structure, chain of command or the absence of same.
21 A. Relationships among the RICO enterprise members.
22 As just partially explained above, there is no significant relationship among the members
23 themselves but all of them interact directly with Gans or his assistants.
24 Gans RICO enterprise consists of at least a dozen different organizations, including specific
25 small businesses plus another dozen or so totally unaffiliated individuals who are retired union
26 members, neighbors of the Mathsons, drinking buddies or fellow drug users with various
27 defendants herein named. Gans has 3-4 fellow law partners involved, probably another very long
28 time former legal partner who is now a Superior Court judge, various environmental engineers
and their lower staff, several insurance executives, RAO Construction Company which at one time
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1 did a lot of the Eureka area concrete work, before graduating onto bigger, better, MUCH EASIER
2 and MUCH more profitable and more corrupt activities, Superior Court personnel, old enemies of
3 Remington that the Mathsons have stayed in touch with to help retaliate against in hurt Remington,
4 etc.
5 B. Continuity. Has this RICO enterprise been in existence long enough to qualify as such?
6 Are its purposes, results, participants, victims or methods of commission and operation interrelated,
7 continuous or entirely dissimilar?
8 If Gans enterprises objectives are carefully considered, it is apparent that the vestiges and
9 original corrupt root acts of this enterprise began long ago, at least in the 2008-11 era, and then
10 blossomed fully as a legitimate RICO extortion racketeering enterprise in the period of 2012-16,
11 and most importantly there is obviously no end in sight because no Remington case here has been
12 resolved, or even close to it. Also as clearly explained, some of the present RICO members have
13 had corrupt dealings and associations for much longer going back at least in the 1990s, however
14 that was not the present Gans RICO enterprise, although arguably it was related as some sort of a
15 distant ancestor. Very simply put here however, this RICO enterprise complained of herein relates
16 to destroying Remington in the Burl Tree only, which objectives did not criminally manifest
17 themselves until about 2012-13, as fully explained.
18 Remingtons two remaining state contamination cases are DR080678 and DR140426, both of
19 which are still very active cases, and which are somewhat in limbo presently in winter 2016-17.
20 However, Gans enterprise continues with a laser focus to win both of those cases 110% and
21 thereafter for simultaneously destroy Remington and the Burl Tree at the same time. Then, if
22 anything is still left of the Burl Tree, Gans and PLOTZs enterprise intends to sue him for
23 malicious prosecution, intentional infliction of emotional distress, punitive damages and as many
24 other frivolous and unjust damages against the victim as they can write with a straight face.
25 RICO activities are related if they have the same or similar purposes results and participants
26 which as fully explained herein aptly applies to Gans present racketeering enterprise.
27 Gans Enterprises methods of committing the alleged predicate acts are very similar, and
28 mostly identical variations of the same acts committed on different days on different parts of
Remingtons property. Recently, the fully explained generally vandalistic and destructive acts are
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1 presently believed to have been almost entirely conducted by Skillings, Kishpaugh, Randall and
2 John Mathson and there are a very wide diversity of types of corrupt acts perpetrated against
3 Remington by this enterprise; but, all clearly have the singular purpose of destroying his will and
4 health, breaking him financially, totally winning the cases and essentially extorting him to make it
5 MUCH easier to give up these fights, fully capitulate and surrender, and then immediately leave the
6 area than to continue to seek justice, which here is defined as a clean-up of the environment on,
7 below and adjacent to Remingtons land.
8 So far, Gans and Mathson have preferred for years to employ their present, mostly rather
9 ineffective, although severely damaging, escalating extortive methods, but as they have not been
10 working very well for them yet, except for their very successful attempts to nearly kill Remington
11 with diseases, and substantially invisible, microscopic pathogens have been rather and very
12 arguably EXTREMELY effective at times, we can now expect increasingly desperate acts of
13 violence, arson, attempted murder, Or perhaps just more stirring-up pathogenic activity and getting
14 it, a simple visual gravity flow, into Remingtons irrigation pumps, systems, lines and water, or
15 worse.
16 Strangely, Remington actually feels a small bit of sympathy during this holiday season
17 (December, 2016, so much of this is partially obsolete) for a few of the possibly unwittingly-duped
18 RICO enterprise members who dont realize fully the desperate and corrupt nature of Gans
19 enterprise and its entirely ruthless and violent nucleus of daily operative soldiers, so maybe they
20 might want to read a little bit about how RICO law works against organized crime. If and when
21 Remington is attacked over his exposure and promotion of Gans Enterprises illegal predicate acts,
22 any act of violence against Remington or his family will have devastating consequences for even
23 the lower level members of this enterprise, if they are directly connected with Gans corrupt
24 purposes in any manner. Such direct connections and proven or inferred connections to federal
25 criminal predicate activity have already been proven in several cases, which evidentiary proofs can
26 only increase now.
27 For example, women like Lawrence, Joy Mathson and McBride for example, who are not
28 usually actually out in the field committing physical acts of violence, vandalism or theft probably
think that they are immune from any repercussions here, and that anything Gans does is just fine;
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1 however, again they dont have to spend six months studying RICO law as Remington has done
2 here, to discover that fallacy should be carefully considered and researched before they relax and
3 get too complacent. Six (6) hours of detailed and comprehensive Google research regarding RICO
4 would be a really good idea for the above three (3) women, but also for everyone else named herein
5 as well.
6 Remington has made it very apparent herein in this detailed discussion that Gans enterprise
7 employs related, distinguishing and consistent corrupt practices against Remington and the Burl
8 Tree which are solely oriented towards the Enterprises stated purposes, schemes and PATTERNS,
9 and common sense indicates and proves that they are not isolated events.
10 In summary then, we have here: (a) A large variety (17+) of federal RICO federal predicate
11 acts alleged here, and in most cases a significant number of some of them, in fact up to more than
12 100 acts of extortive vandalism alone, and also scores of alleged mail and wire fraud; (b) We have
13 longevity here of at least four (4) solid years of serious criminal acts against Remington and the
14 Burl Tree, which are systematically and consistently derived from and rooted in earlier corrupt,
15 unethical or extra-legal activities and/or related causative acts from several years earlier; (c) We
16 have overall a significant number of victims, if the imminent airborne threat to Westgate residents is
17 considered, and the major and numerous downstream water use and fisheries contamination victims
18 are accounted for. Obviously, Remington himself, his wife, daughter, three granddaughters and their
19 friends are all deleteriously impacted here by the Enterprises corrupt activities, and additionally
20 The Burl Tree has all but been destroyed so far, and it has many thousands of customers nationwide
21 and worldwide who are being adversely affected by the Burl Trees demise; (d) As cited herein,
22 Gans employs multiple consistent but separate schemes, devices, unethical tricks mixed in with
23 substantial criminal activities and specific predicate acts, to reach his objectives and consequently
24 by actual exposure or direct personal tutelage, and suborning of perjury from Gans himself, most of
25 the enterprises members and soldiers are familiar with the improper and corrupt objectives, in
26 addition to many of the details of most of the schemes; (e) Obviously, as discussed thoroughly
27 herein, there have been numerous financial, other injuries, and many kinds of significant monetary
28 and/or other damages caused by Gans racketeering enterprise. Those damages are largely to
Remington and the Burl Trees land, property, structures, inventory, goodwill, sales, future orders
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1 and prospects, but also have occurred to the residents of the greater community and environment
2 here and in dollars just at 832 Westgate Dr. alone there have been many hundreds of thousands of
3 dollars of damages, which continue to increase.
4 However, after Gans serial suborning of perjury among his six (6) 2016 SOL trial witnesses,
5 the enterprise now has nowhere to go in federal court, except in a sharply downward, whirlpool-like
6 spiral, in attempting to, among other things: Support 130+ major material false and/or PERJURED
7 sworn statements on the transcribed record, involving dozens of major issues; Continue to attempt
8 to suppress evidence; Continue with their written and oral perjury by five or more witnesses,
9 initially which numbers will soon be multiplied by 2-5; Plus attempt to sustain the many other
10 illogical, implausible and wrong evidentiary rulings, and to carry-them-on into the next trials and
11 very imminent state appeals.
12 In other words, Gans enterprise has tremendous continuity in terms of its purposes, which
13 entirely focus as we have explained on destroying Remington and his cases, and winning all these
14 lawsuits big such that Remington takes nothing, his entire property remains FREE in Mathson
15 hands, in other words with Gans extortion finally becoming successful, and Remingtons land
16 remains just as contaminated as the day defendants deliberately dumped their fill across the
17 property line, and then buried it and further concealed it with organic debris, on top of that.
18 The focus and clear singular purposes of Gans enterprise has remained entirely focused on
19 the above objectives and has remained so for several years, giving it the required continuity of a
20 RICO enterprise under all known relevant Supreme Court case law precedents.
21 C. STRUCTURE of the enterprise. As Explained herein, Gans racketeering enterprise has
22 no specific, absolute, regimented and definite hierarchical structure or rigid military-like chain of
23 command, or military command structure, as such.
24 However, there is also absolutely no subjectivity, question or ambiguity in who absolutely
25 controls it, who gives the orders and exactly what the organization must do, and how it will
26 accomplish that purpose, and who will be used in those mostly corrupt activities. The reason that all
27 of this is SO totally clear is because Gans has exact and absolute minute to minute control over the
28 entire RICO enterprise, and everybody within it for 24-7, and that is the only reason why it is
characterized as Gans RICO racketeering enterprise.
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1 In other words, as explained, Gans is the operating general, Godfather or CEO who issues
2 all the orders, and make sure that everyone is paid very well, through his various and quite
3 numerous subordinates especially McBride, Plotz, Kluck and John Mathson. Obviously, Gans can
4 also work through his superiors or equals, which among others would include Lawrence, Brisso,
5 Nelson and Kloeppel, at a minimum.
6 At the moment, Lawrence (or her counterpart, assistant or possible eventual successor) writes
7 all of the RICO enterprises paychecks and also promptly pays, without discussion or much
8 justification required, 100% of any expense which Gans submits to her. That fact was proven back
9 in 2009, when Lawrence paid at least 110% of all legitimate Gans-Brisso expenses, many of which,
10 even then, were fabricated, bogus and/or double-billed or billed to the wrong case or attorney. In
11 other words, Lawrence is extremely sloppy, and Remington actually complained to her directly in
12 writing, back in 2009, but is quite confident that she totally ignored his complaint and continued on
13 paying false, inflated and padded bills. To long-time executive, CEO and employer of several
14 thousand people, Remington, that merely proves to him that she just doesnt really give a damn, if a
15 billed expense is legitimate or not. Presumably if Remington or anyone was panties expenses from
16 a billion-dollar account, some scrutiny and controls would be reduced, due to human lethargy and
17 laziness. Inferentially, all Lawrence cares about is leaving the office as soon as possible and leaving
18 the rest of this Eureka and Remington business to the eminent and totally relied-upon and trusted
19 Gans. Most of the other witnesses or small business services submit their bills directly to Gans and
20 the Mitchell firm, who in most cases just pays them directly with money received from Lawrence
21 and Allied Insurance, in accordance with principles, policies and financial controls which have not
22 yet been discovered. That will soon change as Kluck, RAO and a new insurer enters this lawsuit.
23 Remington also having been a former executive, administrator, corporate president and acting
24 and working hands-on CEO of his own businesses and also in 4 large corporations or large
25 governmental bureaucracies back east, is therefore very familiar with organization charts and has
26 seen clearly, and also understands, exactly how Gans executes his work and accomplishes the
27 purposes of his RICO Enterprise. It is not exactly rocket science to see how Gans supervises and
28 conducts business with the 3-4 people who are usually with him, or associated during various
case activities. Although somewhat subjective, Remington has made a variety of organization charts
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1 and geometrical, organizational, enterprise relationship charts in Photoshop, several of which are
2 attached herein, or are illustrated in Volume III, to help show diagrammatically, and in color in
3 many cases, the general nature of how and through whom Gans purposes are transferred down
4 through the enterprise, and then into orders and later into instant actions, almost all of which are
5 intended to hurt Remington directly immediately, or facilitate the numerous slow legal processes
6 which are designed to effectively accomplish the same thing.
7 Gans is apparently a somewhat charismatic leader, at least in the circles he travels in, with
8 unlimited funds. Remington will not get into name-calling here, but suffice it to say that he does
9 not find Gans charismatic or impressive in any respect at all, and could put that one hell of a lot
10 stronger in the proper forum. Here, it is the big money that finances Gans entire RICO enterprise
11 that is significant and is making Gans enterprise work effectively. In Humboldt County, and
12 beyond, Money talks and in Remingtons opinion, NO Gans order no matter how corrupt,
13 disreputed or flagrantly unlawful has ever been even questioned, let alone disobeyed or usurped in
14 these cases. Gans and his numerous attorney associates provide adequate legal cover and apparently
15 conveys to his members that if he orders it then it must be legal. That sounds a little bit like the
16 2017 presidency, where that philosophy appears to work better than here, however it is illegal in
17 both forums and is expected to be proven such. No one is above the law, and that includes Gans,
18 Brisso, Plotz and their other top leadership, in particular, plus the other frequently named criminals
19 herein.
20 5. The following stand-alone document was prepared in November 2016 and summarizes the
21 alleged violated predicate acts, and generally who violated them during the last 4 years, at least as
22 was first preliminarily determined, understood and organized during the first three months of this
23 case. For example, the next sequential document that follows this one, the 101- page document
24 which began as a 40-page document in October, what was edited for the last time around December
25 2016, which this time relates the history of the RICO enterprise in terms of specific chronological
26 acts by date, place, crime and participants, etc is a later revision to what follows next, but is also a
27 distinctly different form of presentation. Both of the two following documents in the next 132 or so
28 pages, are probably 95% accurate, but have been superseded and further clarified and delineated
subsequently into March, 2017, and in any event this whole RICO statement will be fully edited as
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1 needed, and almost certainly by January 2018. As explained, the advanced programs Remington is
2 using here simply crash too much to make any more edits within the document itself, and will
3 probably have to be next amended by hand, as a paper copy, which is a pretty laborious task.
4
5 REMINGTON'S NOVEMBER 2016 PRELIMINARY RICO STATEMENT
6 DESCRIBING GANS RACKETEERING ENTERPRISE, THE PRESENTLY
7 DISCOVERED PREDICATE ACTS AND WHICH DEFENDANTS COMMITTED THEM
8 IN THE PAST FOUR (4) YEARS.
9
10 5. (a)24 This early 30-page document was created in November, 2016 and although it is not the
11 final version of Remingtons RICO statement number 5 (a), it is still comprehensive,
12 accurate, useful and importantly presents these predicate acts in a different organized
13 perspective than is done in the final January 2017 RICO statement or in the final federal
14 complaint.
15 Here, The following pages lists the alleged categories of RICO predicate acts, the statutes
16 violated, under 18 USC 1961, and WHO did what to Remington, his property and the Burl
17 Trees property, unless otherwise noted. Revised for 2-3 months thereafter, the WHO did what to
18 Remington in particular are listed clearly without limitation, as many of the predicate acts by
19 individuals scattered throughout this statement were not necessarily compiled yet or listed here in
20 early November. Detailed explanations of Gans enterprise soldiers specific acts and their
21 chronological dates follow below, in the previously prepared 101-page chronology of many, but
22 not all of, the predicate acts committed against Remington in the past four years:
23 1. 18 USC 1951, Hobbs Act. EXTORTION. Gans RICO defendants deliberately and believably
24 causing FEAR in Remington (HEREAFTER R), requiring his FULL-TIME defense, eliminating
25 96% of his work for the Burl Tree, an interstate commerce business, exclusively, see related color
26 chart photos attached within the complaint.
27
28 24
. Recall that 5. (a), in this nationally used format for a thorough federal RICO statement, stated:
Describe In Detail The Pattern Of Racketeering Activity and herein it has taken Remington at least
150 pages to respond to that order, which 150 pages begins on this page.
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1 Gans and Kluck (EXTORTION) of Remington, frequently and intentionally in 2014-16; RAO,
2 John Mathson and Kyle Skillings of Bob Figas in November and December 2012-February 2013,
3 and Wayne Marsh on November 14, 2015, eliminating our scrap iron and used sawmill machinery,
4 hydraulic power units and electrics sales to Oregon, (in interstate commerce); R (for Remington,
5 occasionally) by Randall in 2015-16; John Mathson of Remington from 2012-16 and earlier,
6 breaking windows and irrigation lines, puncturing fragile plastic irrigation ponds and tanks,
7 damaging and/or destroying fences, one pick-up truck, one suspected arson attempt on
8 Remingtons uncompleted structure, serial stealing of redwood, buckeye, madrone, oak and maple
9 burls, machinery and tools, sabotaging Remingtons gardens with Pampas grass seeds (thousands
10 of which GREW), and generally trying to intimidate Remington to MOVE, leaving the hazardous
11 wastes in place, as is. Ds USE of physically violent force or the very credible threatened use
12 thereof, plus the various types of death threats described and inferred, was intended to FORCE R to
13 voluntarily give-up this fight, give Mathson his land rent free and without clean-up and absorb the
14 half a million dollar+ losses.
15 Mathson and Kishpaughs latest extortive acts involves their frequently standing on
16 Kishpaughs driveway waiting for Remington to arrive at about the same time each afternoon,
17 wherein they stand there staring menacingly and hatefully as they attempt to intimidate, extort and
18 make Remington fearful as he gets out of his car, each day. Remington does not know if they own
19 rifles but if they did and it was a little darker, defendants hateful stares would be all the more
20 ominous. Now, They are extortive enough in that they convey: Yeah, WE DID IT AND WHAT
21 ARE YOU GOING TO DO ABOUT IT? [We either just did some new vandalism or We will be
22 doing some more tonight or tomorrow morning before you get here, at the latest.] John Mathson
23 also has another type of a laughing in your face type look which Remington has become very
24 familiar with over the last several years, which says in effect: The deer eating your gardens right
25 now, that I just let in to ravage your property a few hours ago, and the destruction that they and we
26 did earlier today, YEAH, that was caused by me, but you cant prove it, what are you going to do
27 about it, so screw you!
28 FINALLY, All Gans named witnesses such as: Hilfiker, Costa, Evans, Mathson, Kishpaugh,
Skillings, Randall, etc. have all either already extorted Remington or have been scripted to do so
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1 by Gans in the next state contamination trial. That, in accompaniment with their anticipated
2 scripted false testimony THERE, should make many of them eligible to graduate into being real
3 RICO defendants HERE, by the time of the FAC in this case, and in any case probably before a
4 federal trial. Therefore, Gans is becoming analogous to a Pied Piper who is now leading or soon
5 will be, a pretty large array of ostensibly mostly innocent Eurekans, potentially to the federal
6 slaughterhouse.
7 2. 18 USC 201. BRIBERY. RAO of (means bribed) Paul Dalka, Eureka City (Boyd Davis) and
8 the Building Department and Humboldt County since 1998. Brisso of Martel and inferentially
9 Judge Reinholtsen in 2012-16; Gans and Brisso of Peter Esko; Gans of Costa, Kishpaugh, Skillings,
10 Evans, Hilfiker, ETC, and both Mathsons (as explained elsewhere and at SOL trial, as admittedly
11 (on the Voir Dire stenographic record) coached in July 2016); Gans of Randall in 2012-16,
12 especially the later and inferentially Nelson in 2013-14, subject to comprehensive Discovery.
13 3. 18 USC 1341. Mail Fraud (overlaps with violations of California B & PC 17, 200, et seq).
14 Kluck for RAO to Gans in 2012-2016 (meaning Kluck committed mail fraud on behalf of RAO,
15 WITH Gans, plus OTHER kinds of state collusion, conspiracy and fraud); Gans and Kluck with R
16 in 2012-16 (e.g. plagiarized federal judge and frivolous collateral estoppel SJ in 2014); Gans and
17 Brisso with Allied since 2007, but specifically in 2012-16; Kluck with Allied and Gans since 2014
18 FAC where Gans provides all DOE documents, thousands of pages; Gans with Randall, since 2012;
19 Plotz with R, Mathson, Allied, etc since 2014 when he came-on-board the fraudulent ship;
20 Lawrence with Gans, Plotz, Brisso and RAOs insurer we call Allstate, but do not discovered
21 its true name yet; Gans with Jeff Nelson in improperly and deceitfully removing Foget as
22 Remingtons last resort as a local expert environmental expert; Gans with Blue Rock and Hillyard.
23 Hillyard is a new, improper out-of-state, fraud-based environmental expert employed by Gans, as
24 discussed in the relevant sections. Gans latest intimidation and EXTORTION of R, here involving
25 interstate commerce, is complex and will be explained further at the dismissal stages, and after
26 discovery.
27 So far, regarding this crime only, Gans merely committed federal wire fraud and attempted to
28 extort Remington (again) to give-up his lawsuits and lands FREE to the Mathsons by intimating
that Hillyards new testing, 5 years after discovery closed, while trespassing inside the fence on
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1 Remingtons land, would refute all Remingtons testing in the swamp. No details were provided so
2 this was obviously purely a FEAR tactic to worry Remington, which failed in its purpose, again;
3 Julie Gilbride with Remington, Lawrence, ERC, Farallon (Hillyard), Mathsons, Kluck, their
4 perjuring witnesses (mail and phone), etc.; Brisso with Martel, Esko, County Hazmat Division;
5 Olson and RAO with Bank of America, etc., pending discovery of exact RE loans, taxable RAO
6 profits, Olsons massive development along Walnut Drive and beyond, and his money laundering to
7 do all that; Defrauded Farmers Insurance and Remington with Ds (Defendants) bad faith
8 unfounded suit DR080669 suing for a few nails in some gigantic redwoods, a water pipe mitigating
9 major slide damages now in the $20,000 range, and PUNITIVE DAMAGES, BASED ON
10 FRAUDULENT PERJURED TESTIMONY, all AFTER Remington conceded the fence issue and
11 agreed to move it at earliest convenience. Defendants false, fraudulent suit and perjurious defense
12 to the contamination suit was merely a successful effort to intimidate Farmers and essentially extort
13 or BRIBE them into ending their expensive defense with Remington s attorney Harvey Roberts, so
14 as to save Farmers money, which they DID. Gans illegal extortive approach scared farmers and
15 was a successful shakedown and organized crime effort to extort money from Farmers or
16 alternatively to bribe Farmers to remove Harvey who was protecting Remington in the Big suit.
17 Overall Ds tricked Farmers, Judge Reinholtsen, plagiarized a federal judge, spoiled evidence,
18 obstructed justice in the SOL trial by bribing all their own witnesses with exorbitant payments plus
19 Judge Reinholtsen with the inferred promise of a better part-time job if he is fired and indicted by
20 the state or after he may be mercifully allowed to gracefully retire. Discovery will be needed here to
21 prove any of these inferences and allegations, which in all probability will never be finally known
22 or actually proven until we investigate and see what Judge Reinholtsen is doing 3-4 years from now
23 with respect to the Mitchell firm.
24 Plotz is guilty of numerous litigatory ethical violations, which are NOT RICO offenses, per
25 se, but should be and CAN BE considered by this court in evaluating defendants overall unethical,
26 bad faith and/or WORSE litigatory posture towards Remington. A criminal does not perform 100%
27 criminal acts in a given day, but maybe only one in a day with over 99 other lawful or likely also
28 somewhat or very unethical or other obviously borderline acts. BUT, one MURDER in a day is

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1 enough to characterize the overall behavior as CRIMINAL, which Remington does here. Maybe
2 only 1% criminal but in 10,000 acts thats ENOUGH!
Plotz IS complicit in about a dozen actual predicate acts, as is inevitable from Gans right-
3
hand man and principle assistant and daily plotter and confidant. Gans thinks and plots it and Plotz
4
writes and executes it dutifully. In Remingtons October 2015 REPLY to an unethical and
5
borderline Plotz Opposition Remington wrote as follows:
6
Plotz is attempting to deceive the Court and misrepresents the law, prior orders by
7 Judge Reinholtsen, and Judge Breen and the estopped practices here, BY assuming that ALL
8 expert Depositions are to be paid for by Remington just because two were previously 4
9 years ago in a very special case, INAPPLICABLE here.
10 EXCEPT where specifically ordered, as Mr. Plotz, very well knows, all parties pay their own
11 Discovery and Deposition costs as is normal in California, CCP 2025.510, et seq (stenographic
12 costs) and 2034.430 (b), et seq (the experts hourly FEES), ETC. I see the above-cited Plotz
paragraph as a deliberate, CRIMINAL attempt (or in any case, a Plotz-plot- in lawyers
13
clothes, and terminology) to extort and no less than STEAL about $10,000 of Deposition costs
14
from me, by attempting to take that money from me, who had nothing to do with Aveggios death
15
and Fogets job being dissolved during 3 years of DELAYS here (largely sought by Defendants,
16
incidentally, i.e. the STAYS which Remington opposed. As to fact witnesses, Defendants do not
17 HAVE to depose every witness Remington calls at trial, but if they compulsively NEED to, thats
18 on their nickel, in Remingtons opinion.
19 BUT FOR THE STAYS BY DEFENDANTS, FOGET WOULD PRESUMABLY STILL
20
BE HAPPILY IN THE CASE NOT DOING PURE CIVIL ENGINEERING DRUDGERY.
21
Therefore, Mr. Gans and Plotz need to accept some responsibility, but as per the Footnote
22
23
24
25
26
27
28

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below25, written a year later, more likely FULL responsibility, for losing Foget. Losing Foget cost
1
Remington several thousand dollars, NOT defendants as they perpetually whine. Any extra expense
2
to them, ONLY involves Aveggios unexpected death, as Foget was not deposed and hardly
3
anything at ALL was lost there for Mathson.
4
Remington was out arguably in the $35-40k range, or MORE, due to Aveggios death and
5 Fogets removal by Jeff Nelson. Remington was SEVERELY PREJUDICED in at least that
6 amount, but Judge Reinholtsen did not see it that way and inexplicably and unfairly socked Hoyos
7 and Dr. McEdwards February 2016 deposition costs to Remington.
8 Page 10: 18 is the fatal, dishonest, UNETHICAL PLOTZ line, which he does automatically
9 now like his mentor Gans: It is the: as it was with Foget is the FALSE line, the big lie, which
10 could have cost me (R) $10,000 potentially if ignored and/or believed by this or any Court.
Reasonable attorney and reporters fees were also NEVER ordered here, under any circumstances,
11
and it is simply UNETHICAL, DISHONEST, and in my terminology and ordinary parlance a
12
damn lie to write what he did there to try and influence and prejudice the Court. If you want to
13
steal, and commit white collar crime, why not try embezzling money on-line from your bank (Mr.
14
Plotz), or something similar with your sacred PHONE? Please leave me alone and just
15 REMOVE Mathsons hazardous debris from my land. [Remingtons declaration passage
16 continues:]
17 I want $2000 for having to (try and) change everyones opinions pertaining to Esko, plus
18 whatever seems reasonable to the Court for Gans blatant violation of CCP 2034.630 cited in
19 motion page 6: 21-25, which was refusing to automatically and professionally stipulating to two
20 obvious automatic replacements (McEdwards and Figas) that were beyond my control, in order
to save us ALL time, especially the Court, and ME.
21
4) Mr. Gans knows that he STILL has the absolute duty to the Court, and in his attempts
22
to obey his ATTORNEY OATHS, TO always be truthfully and to CORRECT THE RECORD
23
SO AS TO CONFORM TO THE ABSOLUTE TRUTH.
24 25
That Declaration passage was written on September 8, 2015 before this RICO conspiracy was
25 discovered and understood and reflects that Remington merely thought defendants were grossly
dishonest, TOTALLY unethical advocates and accepted that because no court seemed to be
26 worried about it, at that time. Subsequent events, however have proven that SHNs CEO Nelson
27 was improperly influenced, extorted, threatened and/or bribed, as explained, to REMOVE
Remingtons only environmental expert, crippling and effectively decimating his case in one
28 illicit action. It almost worked, however Remington overcame Gans criminal acts yet again with
a better expert from Laytonville, but which was more costly. Bleeding Remington financially to
death is also an important Gans purpose and could also destroy Remingtons case for justice.
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Gans and I know that all his experts made false and deliberately deceptive, evasive
1
Declaration statements (here and especially in the Federal case), based on John Mathsons
2
committed errors and perjuries ABOUT the COMPOSITION OF, PERFORATIONS AND
3
LENGTH OF THE TWIN PIPES.
4
Gans also knowingly via Ferriman sent blatantly FALSE information to Mr. Esko, who
5 apparently had been instructed not to investigate the property personally, and obviously not to
6 gather any contrary evidence fromRemington or John Aveggio (and likely not Ms. Hoyos either), as
7 above;
8 5) See above DBR points for more unethical and/or deleterious and unprofessional statements,
9 dicta and unsubstantiated remarks based on acrimony and anger only, and the other points involving
10 Mr. Plotz and SIGNED BY HIM, under oath, including a few of Gans noticeable edits, including:
(A) The False quote from the Federal complaint involving 4-7 point sources (unintelligible
11
error SWORN to without anyone proof-reading the document);
12
(B) Plotzs false claim and self-serving, deceptive ERRORS that ANY Court ever ordered
13
Remington to pay for Fogets Deposition costs (trying to make that seem like the normal DEFAULT
14
situation, i.e. ME paying ALL Mathsons attorney fees and costs, rather than vice versa as will
15 shortly occur. In a very special, unique case, I paid for two Defendants Depositions of my experts
16 in July 2011;
17 (C) Mr. Plotzs often repeated false statement that Remington is again trying to replace
18 Aveggio with TWO retained experts, etc. is simply FALSE and California attorneys are supposed
19 to be like Gans and mix facts, fiction and mischaracterizations together in about equal thirds.
20 TRUTH should at least be the MAJORITY, if not 90% of a Ds motion document, and negative
hyperbole against pro pers maybe should only be about 10%. Repetitive restatements of false facts
21
and mischaracterizations do not make them true.
22
Plotz and Gans have repeated the above deceptive actions, dirty tricks and unethical,
23
distracting actions more than 200 times over the years, and the DBR Opposing Defendants Expert
24
Augmentation, dated 9/8/15 by belatedly adding the mysterious bribed, free spirit Esko from the
25 County is illustrative. At pages 2-3 (entirety) Remington cites his investigative study and quotes
26 executives Larry Lancaster, Maje Hoyos and Amanda Rudd plus the switchboard operator
27 regarding the TRUTH about Esko, which is NOT the way Gans explains it. HERE, it will become a
28 trial issue.

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4. 18 USC 1343. Wire Fraud, including internet, email and phone. Virtually ALL of the
1
above mail fraud allegations are MORE pertinent to phone and email communications, and
2
WHICH occurred will be developed in Discovery and at trial, which will be LONG getting all this
3
out under oath. Most of the above took place by BOTH methodologies. Some communications
4
occurred by phone mostly such as Ferrimans verbal communications and general confusion and
5 frauds generated among the lower level Eureka area testing technicians, specifically the KNOWN
6 names at SHN, the County, Blue Rock and LACO engineering. Gans communicated to Kishpaugh
7 and Costa mostly by phone to Mathson and then Mathson spoke to them in person, plus they all met
8 frequently with Gans in person to plot their exact perjury. However the perjury was plotted and
9 scheduled on the PHONE mostly and perhaps by email to a limited extent, but NEVER by mail.
10 WHEREAS, 98% of Ds extortive and fraudulent communications with Remington directly were by
US mail and the rest by email or phone (total of 3 times in 10 years).
11
12 5. 18 USC 1503. Obstruction of Justice. Gans has no honest scruples or ethics and has
13 become a feverishly involved player here since about 2014 and his plagiarism of a federal judge
14 because he was desperate and had nothing factual or credible. Gans activities departed from the
15 unethical and over-zealous in 2012-14 when he paid and encouraged his County superior Court file
16 room saboteur to separate, scatter and ruin many of Remingtons contentious lengthy filed
17 documents, and several searches never confirmed that said documents reached their proper judges
18 and courtrooms.
19 Gans crowning CRIMINAL achievement to date was his surprise horrific suborning of perjury
20 among his 5 chief SOL trial witnesses, as discussed. He acknowledged wood-shedding,

21 lecturing and fully indoctrinating and coaching his SOL trial witnesses at Voir Dire in August
22 2016 and gathered a jury which condoned that and did not know that it actually meant wring a
23 perjured SCRIPT for 5 witnesses. Even Remington did not anticipate Gans total corruption and
24 abandonment of all truth. Any case is harder to win if the other side can say anything, get 5
25 witnesses to swear that black is white and make it stick as occurred here. Gans is the ventriloquist
26 controlling a room full of dummies in all capacities, especially his experts, which are now
27 abandoning ship, making trying the contamination cases problematic and likely impossible for
28 Gans.

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1 Better Call Saul is where Gans is today, a criminal lawyer in all senses of that phrase and
2 who eventually should be convicted of being a Northcoast Godfather.
3 Another major crime committed by Gans on February 14-15, 2016 was to alert his soldier
4 John Mathson that Remingtons replacement expert Dr. McEdwards was coming-up from 3 hours
5 away for a deposition and first and only site visit. Gans told Mathson, and instructed him what to
6 do. Surveillance video shows Mathson purposefully, methodically and FRANTICALLY following
7 orders by raking-up redwood needles in an unlikely area good for ONLY that, and spreading them
8 over all asbestos pipes on the site to give the appearance of a benign UNCONTAMINATED
9 pristine forest area, simulating a Love Canal.
10 Gans and Mathsons purpose was clearly to misrepresent the truth to Dr. McEdwards, and
11 knowing what McEdwards had NOT seen on the dump site a few minutes earlier was clearly
12 implicit in Gans questioning. To Dr. McEdwards it looked like Remington had been
13 misrepresenting the scene with doctored photos from 2008, when it was actually Mathson and
14 Gans, who is on video surveying Mathsons progress at broom-sweeping the dumps surface, who
15 severely and feloniously altered the crime site, removed, concealed and falsified evidence to
16 prejudice Remington and benefit themselves. That is similar to OJ going to the Bundy crime scene
17 a few hours after the murder and doing his civic duty of hosing-down the site and removing all his
18 own BLOOD and clothing before it started to stink. That would be unlawful just as Mathsons and
19 Gans intentional evidence tampering here, with the deliberate criminal intent of disguising the
20 magnitude of the crime that they committed here. Gans basic theory is and has been for years: if
21 the crime is hidden, concealed and difficult to discover, then there was no crime and defendants are
22 exonerated at least until future landowners, deaths result from the contamination and/or better
23 future investigations reveal the truth, eventually.
24 Gans thus ORDERED and encouraged Mathson to spoil, alter, remove, conceal and DESTROY
25 material evidence, however happily our very complete site photos from 2008 and yearly thereafter
26 can prove what Mathson did, WHEN he did it, HOW in most cases and WHY. Gans has obstructed
27 the due administration of justice in Department 8, falsified evidence to defraud the Court and
28 Remington and then lied about it. However, by apparently (Remingtons present inference based on
the facts known) having Judge Reinholtsen in his pocket as appearances infer to Remington,
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1 NONE of the above absolutely true evidentiary facts proven by photographs, and when Remington
2 specifically complained of said above facts to Judge Reinholtsen, Remington received no reaction
3 from the court and neither Gans nor Mathson received any admonishment from said court, whereas
4 John Mathson the principal criminal involved here, also sat there, only 20 from the Court for 90+
5 days, like Remington did. In other words, why was Judge Reinholtsen so disinterested in justice
6 and massive, systematic, criminal evidence spoliation, removal and destruction on this major
7 criminally contamination site, which continues indefinitely and its damages to all who surrounded?
8 6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor, pertinent here
9 and absolutely fitting federal statutory definition criteria, perfectly. RAO, Mathson, Gans,
10 Lawrence, and many of the other named and unnamed RICO racketeering co-conspirators, are the
11 primary racketeering leadership presently (with Kluck and others presumably to soon to gain
12 GREAT importance) and THEY have gambled, and continue to roll the dice daily that R would
13 never discover their buried criminal secrets, and John M (Mathson) continues removing and
14 covering (with redwood needles) new evidence daily as it emerges to minimize accurate
15 photography and impact. Said defendants now have at least one million dollars at stake here on the
16 craps table and have bet they can keep Remington and the current State judge the Honorable Dale
17 A. Reinholtsen at bay here, away from REAL knowledge and discovery and then OUT WAIT R,
18 and hope his health slips further to where he can no longer breath and/or care about fighting this
19 injustice. The exact definitions of 18 USC 1511 (b) defining a gambling business fits these facts
20 perfectly and 100%, see also 1955. The above gamble has been going-on since 1998, but
21 CONTINUES in every parameter, and THIS is a continuing case, because it was timely filed and
22 ALL criteria of California state continuing nuisance/trespass are met and presumably the same
23 apply federally as to the continuing federal allegations.
24 The criminal RICO conspiratorial enterprise was not begun in its present form until about
25 December 2012, and it was not recognized as a criminal organized crime-like RACKET until 2013-
26 14, or in its present totally transparent structure until September 2016. The criminal cover-up and
27 the total dedicated attempt to DESTROY Remington no matter what extra-legal perjury, obstruction
28 of justice and extortion, ETC it took, did not clearly manifest itself until a known day in late July
2016 when Remington unfortunately revealed his plans and methods of destroying their only
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1 partially credible statute of limitations witness Skillings. WHEN Gans heard he had NO CASE
2 then, he desperately spent a week (which fortunately for him coincided with several days off for R
3 to go to Oregon, etc) coaching 4 witnesses to back-up MAIN BOSS PERJURER John Mathsons
4 bogus, scripted story, never revealed in Discovery or ANYWHERE until opening statements in late
5 July 2016.
6 Today, as per this complaint and charts, we can clearly identify about 35+ conspirators
7 involved in the cover-up, most of whom just think they are doing their job or duty against the hated,
8 slandered Remington, who Gans portrays as the devil, which eventually will be reversed into
9 what is TRUE here. FEW of the 35, likely only the attorneys and a select few others (the REALLY
10 good people have LEFT the conspiracy previously, people like Hubbard, who refused to obey Gans
11 evil orders previously and possibly Plotz and Ferriman to name two others who may be waffling
12 and possible other states witnesses in a criminal trial).
13 7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite, as
14 his most successful, deceitful, federally HIGHLY ILLEGAL device is to write the script carefully for
15 each of his own witnesses to fit HIS false facts, HIS NEEDS and what the witnesses integrity and
16 degree of conviction and memory is on each issue, for which Gans plans to call on them to
17 gradually FILL-IN the deceptive painting, as it were. So far, Gans court room paintings have
18 been to take a true image of the truth and then paint over it, totally painting-out all semblance of
19 truth, with a totally false image of his own design and imagination, fitting his purpose.
20 So far Gans has procured PROVABLE perjury (which we will now be able to prove by
21 omission cross-examination techniques in the next trial) in the State SOL trial and Remingtons job
22 will be to get all that repeated in Federal depositions, declarations and at a federal trial so that after
23 spending all of that time and energy, the NEXT TIME that Gans pays his witnesses to perjure
24 themselves on most material issues, there will be jail terms passed out at the trials conclusion, and
25 not just several idiot jurors shaking the hand of Gans, the master manipulator, puppeteer and
26 perjury master. Future publicity will now be required to reach those exact idiot jurors, plus future
27 possibly naive juror panels, who were mislead by Gans and the Court and confused and highly
28 irritated by Remingtons uneven, improper and likely impossible preparations for irrefutable

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1 multiple witnesses against one. Next time, after a few years of preparations we will get closer to
2 the TRUTH.
3 Here, it is easiest, and the shortest and fastest way to say it, that Gans coaches, unlawfully
4 instructs, writes and wood-sheds the testimony of, 100% of his witnesses, as per the 2016 SOL
5 trial transcripts and pre-trial representations of Randalls, Evans, Skillings, Olsons, Hilfikers,
6 Costas, Hillyards, probably Nelsons and others projected testimony in March to August 2016.
7 There was only one qualified exception to that rule in the last 2016 SOL trial, wherein Pulley was
8 relatively straight in most of his testimony while under oath, as fully explained herein. Only his
9 NON-SWORN pre-trial work was unethical and wrongfully written by Gans for his signature but
10 not his sworn oath. Specifically, one example of that (of many) is Pulleys primary MAP-chart of
11 the two properties at issue and the survey and Agreed Fence line drawn on them, probably pretty
12 or VERY accurately. Since Pulleys surveyed line has been long conceded as accurate-enough that
13 work was not at issue. [This Pulley discussion like most of the detailed discussions here have been
14 substantially updated in subsequent months, and into mid-March, 2017, and therefore was not
15 updated or even read during this last cursory proofread]
16 What WAS WRONG and is a material misrepresentation drafted by Gans is the so-called toe-
17 of-the fill line which Gans drew, as a deliberate fraudulent UNDERSTATEMENT of the known
18 proven facts on the ground, as sworn to by plaintiff here, who is the ONLY person on earth who has
19 correctly delineated the edges of the fill in his thousands of hand shovel and mattock excavations
20 all over the fill, at and ON its edges and a few feet or MORE BEYOND the fill where his 18
21 planting holes encountered ONLY native soils. Remington determined and specifically recalls the
22 soils at or just BEYOND the fill, where plants mostly THRIVE, and therefore HE and he ALONE
23 know where the fill is and is NOT. Mathson, Gans and Pulley have no idea at all where the fill ends
24 as it is ALL obscured by 2-10 of redwood needles and brush and then mostly (99%+) buried under
25 additional sand, organic debris and some eroded dirt at the bottom of the dump.
26 Simply put, Gans told Pulley where the fill was and understated it by at least 100% in all 3
27 parameters. In other words, it was twice as long at least twice as wide and at least 3-4 TIMES
28 deeper in 90% of the prescribed dump area. Remington has detailed 3-D charts of all dimensions

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1 based on scientific measurements, borings and several THOUSAND hand excavations up to 3
2 deep, plus many other related bits of evidence related to depths and composition.
3 What that means is that what Remington swore to at the SOL trial is accurate: Pulleys toe-
4 of-the-fill lines, which were only estimates as he admitted and wrote, and his honesty is
5 noteworthy and commendable there, are WRONG by 4 times linearly and 8-12 times overall as to
6 VOLUME and how much encroaching material RAO and Mathson deposited here in 1998, which
7 materials substantially MOVE down the 50+ degree slopes in every rain, and CHANGE over
8 time accordingly. That variance over time in combination with the reasonable, easy remediability
9 of the sites, mean that we have the classic definition of a continuing nuisance/trespass here, which
10 damages may be SUED for every 3 years until removal of the hazardous materials. THEREFORE,
11 Pulley was tampered with pretrial but did not perjure himself further at the SOL trial,At least not
12 yet. Not all witnesses bend to Gans evil wishes and scripted lies, even for the substantial BRIBES
13 offered of 2-10 times their normal hourly value to society. Paying Joy Mathson, Costa, Skillings
14 and Kishpaugh 5-10 times what they are worth to anyone else explains about all you need here as to
15 corruption and the ability to buy virtually ANY testimony. John Mathson has the most to gain or
16 lose here so his testimony is 100% fluid, and if Gans needs Remington to be a murderer then John
17 Mathson will be the eye witness and the one who plants the OJ glove or shell casings in
18 Remingtons side yard where Remington allegedly practiced, etc. [This is NOT hyperbolic, as it
19 has become clear to Remington and eventually to ALL, that Gans corruption and desperateness to
20 win without regard to truth, legality, morality, ethics, committing criminal predicate acts or
21 engaging in LAWLESSNESS, is his over-riding method, which he ruthlessly pursues.]
22 HERE, he may well bring-down ALL of his associates as equally culpable for ALL damage
23 Done to Remington, the environment and the community residents, if they engaged in even ONE
24 predicate act themselves as the ENTIRE ENTERPRISE is now inextricably linked together, and
25 now they all hang-together, LIE and cover-up, or they ALL FALL, if Remington can present this
26 case clearly.
27 There is also caselaw which indicates that even without a federal criminal predicate act by an
28 enterprise member, if they have otherwise acted unethically, illicitly or somehow illegally, but not
necessarily in violation of federal 1961 law, and also they clearly caused damages to plaintiff or
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1 his family, or are otherwise clearly implicated as being important foundational or irreplaceable and
2 key linking members in the Enterprises hierarchy, they may also be liable for all damages, when
3 the trier of fact eventually designates who was responsible for which part of the treble damages, or
4 perhaps only for single damages, where applicable.
5 Also, we need CRIMINAL (DA,US attorney and/or FBI) authorities to help-out here and
6 presumably lead to many more illegal facts and many more so for undiscovered predicate acts by
7 Gans, et al. Remington would estimate that a proper criminal investigation now will lead to a
8 doubling and/or tripling of Gans Enterprises known State and federal crimes, and if thereafter
9 implicated in a FEDERAL investigation or by the court and triers of fact in this case, then the
10 penalties in federal court are incalculably HIGHER than in Department 8, where anything appears
11 to go at this point, and California attorney ethics are left at the door, and effectively scoffed at
12 by all concerned, or so it appears to Remington in 2016, in any case. In other words, Remington
13 believes that federal courts are going to take all of these ethical and criminal violations much more
14 seriously than there being taken so far in the present Humboldt County Superior Court.
15 Additionally, SEVERE felony RICO extortion, bribery, blackmail, intimidation, coercion, and
16 Hobbs ACT FEAR were perpetrated on and engendered in Figas in 2012-13, as previously
17 complained about in depth in the DR140426 complaints. SIMILAR, equally egregious and
18 unexpected extortion (or conceivably the other possibilities to be discovered) was perpetrated onto
19 Remington witness and remediation contractor Wayne Marsh, of Elk River, on November 14, 2015.
20 This episode has been amply complained-of throughout and needs a deposition to determine the
21 exact statements, details and CRIMES committed. SO FAR, both Marsh and Remington have been
22 severely damaged by this latest corrupt act by defendants enterprise, and meanwhile the road-in
23 and REAL excavation of and determination of the horrors buried by RAO remains undetermined.
24 RAO is desperate to keep their crimes secret and what lengths their enforcer Skillings will resort to
25 is a real FEAR, and is not yet determined.
26 It is not hyperbolic to allege that ALL of the above acts were inflicted on Figas who was VERY
27 upset about it and he is a VERY tough man ordinarily. Marsh has not yet been spoken to about
28 violating his contract and promises, and will emerge as a larger figure here after his imminent
examination and deposition.
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1 Gans clearly gave the order about Figas through Mathson, and then to SKILLINGS who is the
2 Luca Brasi (Don Corleone-Godfather- MAFIA, organized crime-type) executioner and obvious
3 psychopath, has the courage and anger to do the EXECUTIONS. Here, the crime was common
4 extortion and blackmail, centrally but more details are needed from ALL involved and UNDER
5 OATH, because Figas is still afraid to say too much about those traumatic events. John Mathsons
6 mentioned spoliation of evidence only HOURS before the known date and EXACT HOUR of
7 Remingtons only environmental expert Dr. McEdwards, and also preceding Maje Hoyos
8 deposition a day later was very carefully and artfully orchestrated and executed by Gans. Similar
9 nasty events occurred in 2012 before Mike Fogets visit when John Mathson intimidated and made
10 Foget and R afraid by yelling violently at Foget (and by implication Remington standing 15 feet
11 away), as though he might SHOOT him, or us, at any moment. MANY other provable cases of
12 witness tampering, extortion, bribing and intimidation exist and can be proven with written
13 discovery and many depositions, some short ones, others NOT.
14 For example, without limitation: Gans and Ferriman improperly worked-on Nelson (the boss
15 and CEO over BOTH Rs experts Aveggio, and then Foget after Aveggios premature DEATH, and
16 now an enterprise defendant) prior to August 2014 (when Remington learned about it) to eliminate
17 Foget from Remingtons case severely CRIPPLING it for months; Gans bribed, misrepresented his
18 criminal case and intimidated Randall into cooperating in his bogus visual nuisance case which
19 was frivolous and settled below nuisance vale in order to remove Harvey Mathson and other
20 financial drains from this case which potentially could have cost Farmers well-into the mid-6
21 figures of dollars. See extortion above. Just because a crook has a law degree does not mean that
22 everything he characterizes as a settlement is thereafter above scrutiny, honest, legal and beyond
23 criticism under the litigation privilege or CCP 425.16. Also provable tampering occurred with
24 Plotz on Mathson and their 5 other SOL trial witnesses, only 4 of which were used; Gans on
25 Schwartz; Brisso on Esko and Martel, ETC.
26 8. 18 USC 1513. Retaliation Against Multiple Witnesses. Gans and Plotz (and Judge
27 Reinholtsen) retaliated against star witness Plaintiff Remington, as alleged partly above, under
28 extortion. THERE, Gans orchestrated his gang of thieves, liars, driveway auto mechanics, trailer
trash, old union and drinking buddies, drug users and dealers, drag racers and desperadoes needing
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1 money to pay their house mortgages in foreclosure, etc., so in the representative specific case of the
2 Kishpaughs, bribery was direly NEEDED and WELCOMED by them to make their August and
3 September house payments, or possibly just back payments, as their house is about $65,000 in
4 arrears and being auctioned-off in November 2016.
5 A. Gans, Skillings, Olson and Mathson ganged-up on Figas and threatened to damage (and
6 presumably ARSON and totally destroy) his huge under-insured $100,000+ excavator, possibly do
7 violence to his person or family, and overall, believably SCARED him severely. He desperately
8 needed money in late 2012, yet pulled-out of an ongoing lucrative $20,000 Remington job of
9 excavating, filling-in a gigantic slump hole and hauling more than 75,000# of scrap iron and
10 machinery to Oregon. Figas was then a witness and still is in an official proceeding; as was
11 Remington when Mathson similarly executed his coercive threats and VANDALISMS beyond
12 fences and broken windows to Remingtons two vehicles parked on or near Westgate Drive. In
13 violating this statute, defendants also serially tampered with and/or interfered with Remington,
14 Figas, Foget, Tidwell and all of Remingtons intended witnesses in their LIVELIHOODS as related
15 to their testimony against said defendants as related to the latters committing federal crimes or
16 offenses. Fine or imprisonment is the penalty THERE and for all of these federal violations.
17 Conspiring with Gans to commit these crimes is also a federal offense which reasonably
18 applies to ALL named defendants and many of those reading this CLOSELY, and seriously (YOU
19 know who you are) will be hung, along WITH Gans, Skillings, Kishpaugh, Nelson, Randall, Plotz,
20 et al, or whomever the first person who turns states evidence seriously implicates and/or who is
21 CONVICTED of a felony, on some other evidence, etc. Example: If Gans, Skillings, Kishpaugh,
22 Olson, Randall, Costa, John Mathson, or some less probable enterprise member, just somehow
23 intentionally or accidentally MURDERS Remington, and that criminal incident just happens
24 to get caught on a Remington surveillance video, then potentially all 35+ here, who are actual
25 RICO enterprise members doing Gans usually evil and corrupt work for him, will potentially
26 ALL go to prison for SERIOUS terms, whether they have young children are not, if this civil RICO
27 enterprise is either proven HERE or subsequently in the criminal courts, either state, federal or
28 BOTH. There are also other criteria and factors that must be considered by the court which are

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1 explained elsewhere, but were not fully known to Remington in September-October 2016 when
2 most of this was drafted.
3 John Mathson, under Gans specific orders and with Gans known knowledge, approval and
4 acquiescence has serially vandalized Remington since 2008, which R has vociferously complained
5 of previously to ALL involved here, including to Gans and Judge Reinholtsen in writing and orally,
6 and the sheriffs deputies, eventually accomplishing nothing.
7 Gans, however always thinks Mathsons vandalism is FUNNY, when he has been
8 confronted by Remington, in person at several hearings, or at least Remingtons predictable
9 REACTION to it is perfect for them! Gans invariably just smiles, chuckles a bit, and smiles
10 inwardly and tries to pretend that he doesnt know what Remington is talking about while he tries to
11 keep his smiles from becoming audible. Never has Gans or Mathson exhibited any anger or any
12 outward sense that they were being unjustly accused of something they didnt DO or know anything
13 about.
14 Sympathy or compassion and/or any admonishment of his client?! Are you kidding? Remington
15 actually watches Gans interactions with John Mathson very closely and it is obvious that Gans
16 highly approves of Mathsons criminal acts especially if theyre not caught on surveillance camera.
17 Whether DEER, bears spreading garbage (requiring 30+ minutes to pick-up, and then remove
18 across 200 and up a mountain) or human vandalism of expensive very large Anderson windows, a
19 non-oped good Silverado pickup, a forklift, and dozens of redwood burls, Gans always manages to
20 clearly convey that he thinks its GREAT, and that therefore his overall master plan is working.
21 Hence Gans always seems cheerful and encouraged about the serious damages and crimes
22 someone is perpetrating upon Remington, and infers that possibly Remington should just bend-
23 over, capitulate, GIVE-UP now, and stop their TORTURE.
24 THIS complaint and initial summary of some of the federal law violations committed by Gans
25 enterprise members, and begins with the more serious organized, criminal acts against Figas
26 beginning about 2012, which continued into October 2016, (as this was initially written) when John
27 Mathson cleverly and unexpectedly removed barbed wire and wire fencing DEEP within
28 impenetrable brush and hedging at the Southeast Cooksey corner at Westgate. Next Mathson
penetrated the fence with wire cutters, pushed down fencing with his hands and arms (with 70-120#
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1 of force, in a manner that no deer could accomplish) and hand-removed two 50-100 pound burl
2 slabs by grabbing, lifting and then sliding them 4 West where they were not noticeably moved,
3 viewed from inside the yard. When accidentally discovered about October 10, 2016 it took an hour
4 of crawling in dirt and mud, patching, placing a large 3 x 5 wire screen patch in the hedge line
5 itself and then lifting said redwood burls back over the repaired area to execute a semi-permanent
6 fix until the next HUMAN intervention. THOSE holes were large enough for burl slabs to be stolen
7 and deer and bear to vandalize Remingtons gardens for weeks, and that is what occurred, as that
8 particular hole was in an inaccessible area and rather difficult to discover. Subsequently in both
9 November and December 2016, Mathson cut additional fence holes, in that area and in other areas,
10 leading to additional vandalistic acts.
11 Remingtons 2016 SOL trial witness Russ Biassca was also apparently harassed after his trial
12 appearance, by agents of Gans and RAO.
13 Finally, as Brisso is believed to have conspired with, influenced and is inferred to have
14 otherwise tampered with the state judge in this case, especially and perhaps ONLY in summer
15 2016, by probably offering permanent part-time employment after retirement from the bench, for
16 life in effect, and if so, understandably Judge Reinholtsen has a warm-spot in his heart for all
17 defendants, and obviously felt some favoritism for his former long time law partners initially,
18 especially when the going got tough and defendants needed some help.
19 Hence this RICO suit MUST be, or at least is preferably filed out of the area and in Federal
20 Court for rather obvious reasons, as clearly in view of this overall document and partial indictment
21 of the local state court, it would be inappropriate and probably not fruitful for Remington to bring
22 these types of RICO charges in state court before Judge Reinholtsen. Judge Reinholtsen is a nice
23 and fine man who has treated Remington with respect, however he has done nothing to reduce
24 Remingtons grave suspicions expressed herein, which although inferred and alluded to herein, will
25 take several years of discovery now to sort-out and to reach a just outcome. Meanwhile, obviously,
26 for reasons which need not be written here extensively, Judge Reinholtsen would not be the
27 optimum choice to adjudicate the ethical and corruption charges alleged here, including oral and
28 written perjury in signed declarations, obstruction of justice, bribery and witness tampering, ETC.
additionally, as expressed elsewhere, he is believed to be biased in favor of Gans, Brisso and all of
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1 his former law partners, plus he is not the modicum of ethical character, and has never entertained
2 any of Remingtons ethical accusations, and it could be strongly inferred that Remingtons criminal
3 accusations, against his law partners would even be MUCH less welcome.
4 Substantial discovery in the sensitive areas mentioned here, involving state judges in
5 particular, will be needed to attempt to PROVE (or to refute) all of these innuendoes, allegations
6 and possible criminal activities, and assistance from the County DA will be sought shortly and
7 would be invaluable to penetrate these Courts, and file room conspiracies, for example, which
8 Remington as an outsider AND detested pro per can not even attempt or hope to duplicate,
9 obviously. Additionally, as fully explained elsewhere and not again repetitively here, Brisso is
10 alleged by formidable witnesses to have previously controlled the Humboldt County Courthouse
11 and especially the District Attorneys Office, and he is strongly believed to continue his improper
12 influence with the district attorney, based on evidence Remington has seen firsthand in 2016.
13 Every few weeks, more and more unethical, irregular and/or borderline criminal acts occur
14 from defendants and/or from within the superior court system. For example, most recently the
15 Department eight court held a hearing and directed that a copy of todays court minutes be sent the
16 plaintiff. Six (6) weeks later that has not occurred, nor at 18 weeks (or EVER presumably) either,
17 and Remingtons three messages to the Department eight clerks (Janice, et al) requesting some sort
18 of 10 word verbal summary of what occurred, have not been returned, nor was his written inquiry
19 answered. Therefore today, Remington now has no idea what the status of Judge Reinholtsen is in
20 DR080678, or who the judge is in that case, because apparently a different judge was assigned to
21 DR 140426, which Judge Reinholtsen had previously been coordinating, but voluntarily gave it u,
22 evidently. Periodically, Remington has been removed from the courts service list by said file room
23 saboteur, complained of throughout these documents, and quite possibly that is occurred again. We
24 just dont know what goes on there, and only a DA investigation could actually find out the truth
25 about why Remington has been abused so badly in Humboldt Superior Court, for the last eight and
26 a half years.
27 B. All of the definitions of 18 USC 1515 (a) (1), (3) & (6) and (b) apply above, to Gans and
28 his RICO enterprise, including knowingly making false statements, omitting information,
intentionally concealing facts, and destroying material evidence, with the intent to mislead
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1 Remington and the state court. Gans has corruptly persuaded and/or attempted to persuade
2 Remington and the state court by withholding, concealing, altering AND destroying documents or
3 other information. Numerous examples of those activities were provided for about 100 days during
4 the 2016 pretrial hearings, and included transgressions and crimes such as: spoiling material
5 evidence on the contaminated sites, intentionally concealing facts about every aspect of these cases
6 as alluded to throughout this complaint; intentionally making false statements, concealing facts and
7 omitting material information again, on virtually every subject touched upon for three months in
8 pretrial hearings, most of which is recorded in a stenographic transcript; suborning perjury in five
9 crucial trial witnesses (only 4 of which testified and actually committed felony perjury), concerning
10 the sole material issue in the SOL trial, etc. ALL of the 18 USC 1515 definitions cited above
11 apply directly here to defendants actions, as led by Gans and executed by his principal soldiers
12 Mathson, Skillings, Kishpaugh, Costa, Randall, et al plus defendants experts and the others named
13 herein.
14 9. 18 USC 1952. Barring interstate travel with racketeering and/or gambling income,
15 BOTH directly applicable here with little imagination or creativity required. Additional discovery is
16 required here but MANY of the named and associated defendants are KNOWN to have traveled
17 interstate or BEYOND between 2012-2016, which would specifically include Gans in August 2016,
18 Lawrence, Plotz, Olson, Skillings, Kluck, Randall, Nelson and the Mathsons, to Oregon, etc. ALL
19 of them and the other associated crime syndicate racketeers named or associated in this enterprise
20 are living-on and earning illicit racketeering funds derived from this vast cover-up, hence any and
21 all discovered trips from 2012-2017 are implicated.
22 If Gans was paying his fines or in prison he would not be harassing Remington here for more
23 than 9 years so far and reducing the Burl Tree sales to near ZERO (as proven elsewhere) as a result
24 of no burl products being made, existing orders not filled, huge wholesale deals lost in 2013-15
25 (Jagger, Buck, Sandberg, U.S. Justice Department, and many others), and no sales even being
26 attempted, in many cases and time periods.
27 Similarly Lawrences income is substantially augmented by her success at keeping R distracted,
28 defending frivolous motions and unable to devote even 5 minutes a day to the Burl Tree, most
days, presumably until he dies of (or indirectly FROM diseases derived from) defendants toxic
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1 materials on his land. NOT all, but a portion of HER income derives from Unjust Enrichment and
2 from the several hundred thousand dollars she has saved Allied Casualty to date, which savings are
3 being erased slowly with her escalating and never-ending continuing legal costs. Most of the
4 participants herein, like the environmental engineers are believed to have used portions of their ill-
5 gotten pay checks to leave the state on business or pleasure, as well imminently be discovered.
6 Gans new environmental expert Hillyard works FROM Portland, Oregon and traveled HERE
7 in about February-March 2016 to do unknown borings, 5 years outside of Discovery in any of the
8 cases, with the INTENT to intimidate Remington and to attempt to SCARE and instill Hobbs Act
9 FEAR in him. In the flurry and blur of major complex trial preparations, somewhat arduous for an
10 old inexperienced pro per, Gans enterprise partially succeeded in his goal, by costing Remington
11 considerable further time and expert costs trying to figure out what Gans was up to, and to defend
12 against it.
13 Kluck also travels and vacations A LOT, out-of-state largely, according to further discovery,
14 as does RAOs carrier Allstate, or whomever else is eventually discovered to be representing
15 OLSON and paying Kluck to do so, as it clearly is NOT Olson or Skillings who pays Kluck, at this
16 point. Kluck sends an invalid, unenforceable, non-statutorily approved unavailability letter about
17 every three months, and seems to take a lot of vacations, so he, above all here, is operating off the
18 ultimate money laundering situation in this case which is RAOs unjust and mostly criminal income
19 from 1998 and derivative corrupt real estate endeavors, since then. Since Kluck has literally done
20 nothing in substantive defense of RAO in these cases, we have not had to test his leave me alone
21 Im on vacation letter, but will soon be doing so in this federal case. It does sometimes happen in
22 the legal system that vacations have to be postponed when substantive matters are scheduled which
23 need to be resolved sooner and not never. For example, there will be numerous discovery deadlines
24 to adhere to, vacation or not, but fortunately Kluck has at least four partners that can ably,
25 competently and youthfully fill-in for him while hes in Tahiti.
26 10. 18 USC 1956. All Money laundering uses are illegal, and ALL Defendants named in this
27 RICO enterprise are implicated in spending illegal laundered money. ALL money spent by Gans,
28 the Mathsons, RAO or any defendants has been affected and INFECTED by the illicit unjust profits
originally criminally STOLEN from California and Remington primarily in the 1990s but which
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1 damages accrue and increase like compound interest. Gans alone has made more than $2-300,000
2 from frivolously battling Remington who has an obviously just cause, where only a few years ago
3 Gans, Lawrence and defendants offered Remington about $100,000, as what was supposedly a
4 reasonable and settlement cleanup cost to them, and which their former inept, corrupt and now
5 totally discredited expert, Ferriman, once incredibly, grossly, incompetently, and now provably
6 intentionally FRAUDULENTLY under bid at $10,000, before being tossed from the cases.
7 For example, Allied, Mathson, Olson, Allstate etc. should have paid Remington about
8 $200,000 just for the cleanup alone many years ago, plus at least $12,000 per year rental for the 1/3
9 acre appropriated by them to support Mathsons entire development. That 1/3 acre is not just ANY
10 steep residential redwood forest of minimal resale value, but VERY important to Remingtons
11 garden hubs, irrigation, aesthetics, etc. Today, Remington has dozens of other major damages, costs
12 and emotional and physical injuries which money cant really fix, or adequately provide any
13 reasonable compensation.
14 Said 1/3+ acre area is also CRUCIAL to the Mathsons entire development hence they
15 stole (or appropriated) it in 1998, as a crucial FOUNDATIONAL part of their project. WITHOUT
16 THAT STOLEN KEY PORTION OF REMINGTONS LAND, ALL OF MATHSONS
17 PROPERTY AND EXTENSIVE DEVELOPMENT WOULD ERODE AND COLLAPSE DOWN
18 THE MOUNTAIN IN A FEW YEARS, or in one 7.2-7.8 earthquake, which historically come
19 about every 10 years or so. THAT fact explains why defendants have fought for 10 years to defeat
20 and/or kill Remington, so they can keep that VALUABLE and foundational piece of mountaintop.
21 They could have bought it or traded for it in the past under various settlement proposals, but now
22 defendants (Gans, Lawrence, Mathson and RAO, particularly) HATE (and/or FEAR) Remington so
23 much and have wasted so much fighting him that they need to save face and crush him totally now,
24 and also make some more cash from his insult.
25 Those later factors are not coincidentally the very OBJECTIVES of Gans and Lawrences
26 enterprise. The latter presently skates free by being a litigation privilege-coddled participant and
27 insurer, but who WILL be deposed and her true role in the extortion rackets will be probed, in
28 depth.

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1 Remington would also argue that presently believed chief adjustor Linda Lawrence has
2 probably saved Allied Causality so far (and undoubtedly taken it as salary RAISES for herself, as
3 a BIG bonus) close to $500-700,000 from Remingtons eventual just recoveries here, including
4 saved INTEREST.
5 That amount compounded is more than the $3-400,000 estimated above around 2011, and
6 merely confirms the fact that Allied, essentially the only financier here so far, is making-out like a
7 bandit in screwing Remington here to date. UNTIL Remington gets an aggressive attorney (TWO
8 are currently interested) working for his unlimited fees in this RICO case, Ms. Lawrence is riding
9 high and feeling VERY smug indeed. Gans inferred that in the June 2016 courtroom corridor
10 scenarios outlined herein, as he extorted, coerced and SCARED Remington, while explaining how
11 ANGRY Lawrence is, how powerful they ALL are cumulatively (as an enterprise, we NOW learn)
12 and what the dire consequences of all that will be over the next 10-20 years, for Remington,s
13 daughter and his grandkid heirs.
14 Per 1956 (c) (7) (E): Mathson, RAO and all their co-defendants and enterprise associates
15 profited unjustly from the riches and/or huge illegal profits originally made by said defendants (plus
16 the City of Eureka, and others named indirectly) from their original criminal actions against all
17 levels of government in the illegal hauling, dumping and burials, and presumably thereafter the tax
18 authorities at all levels, as NO TAXES were paid by anyone on the above illicitly gained wealth.
19 That includes the Mathsons especially who added at least $150,000 of RE value, which was
20 TAXABLE as a gift, plus they are believed to have received CASH and other valuable work
21 considerations, like life time protection and support from Skillings, PAID FOR by Olson, as the
22 entire Olson (RAO) huge $150,000 illicit dumping and excavation project was performed at NO
23 charge to the Mathsons. That is extremely significant for any one aware of the HUGE costs of
24 properly operating, maintaining, servicing and fueling diesel trucks, equipment and paying their
25 qualified operators for running that massively expensive equipment for 3-4 months, costing at least
26 $150,000, per discovery. Thats a pretty generous and REALLY big gift from Olson to the
27 Mathsons who barely knew each other then or NOW. All this is being investigated now, as you
28 read, by stronger others concerned with societies public interests in promoting justice and
punishing transgressors properly. This is a civil RICO enterprise case, however Remington has
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1 discovered the criminal enterprise, and will develop it fully here, however others will eventually
2 see exactly how far and deep the criminal tentacles of this enterprise have reached.
3 Additionally, the huge amount of money saved just by so-far beating the federal (and state)
4 environmental statues, such as CWA, RCRA and CERCLA (here) is also LARGE. The insurers and
5 attorneys for example by NOT paying out the approximately $500,000 which was due Remington a
6 few years back, if invested at 10% compound interest, about 8 years ago, amounts to substantial
7 savings. Not enough to justify all this perhaps, in retrospect, but overall, even after paying 9 years
8 of litigation expenses, Allied, for example (Allstate, et al) are still WAY-AHEAD, hundreds of
9 thousands of dollars, if they can CRUSH Remington legally, kill him or make him go away from
10 the area, etc. Wouldnt take MUCH, after a cleanup to sell and leave this hostile, lower class (in
11 every way) neighborhood.
12 Now, Remingtons land is unsalable so leaving is impossible.
13 Hence all defendants are doing great financially while Remington and the Burl Tree have
14 blown ALL their remaining cash into legal costs and time spent battling Gans and Allied and not
15 making burl products to sell which with TIME could be almost unlimited with Remingtons still
16 remaining $600,000+ burl inventory inside and out. Damages in this case for 2012-16 are sought,
17 continue and also all Ds purchases in that period, including the NUMEROUS known MAJOR RE
18 purchases since 1998 (which contributed income in the relevant cited period), and everything
19 ELSE, is now subject to analysis and scrutiny as to damages, tax evasion and related issues.
20 The $20,000 illicitly paid by Farmers to Allied, from Remingtons perspective, was in effect
21 an important extortion payment. Remington maintains it was an extortionist bribe to Farmers,
22 with the obvious effect of leaving Remington without an attorney in the MAIN contamination case,
23 where all the money was potentially available to possibly lose, by both insurers. Apparently what is
24 just a common bribe or extortion to a person in Remingtons position, is evidently legally
25 considered insurance and avoiding a risk to the insurers. Defendants may argue it was a
26 reasonable settlement, but of a frivolous case which had no chance of prevailing in an honest
27 system based on good faith, REAL, scientific facts and not Gans frauds and perjury, etc., as
28 explained in the 100 pages of Severance documents. Here, settlement is a meaningless concept
proffered by Farmers to offer a bribe to Allied of $20,000 to avoid the likely loss of much more
347
1 than $100,000 had Harvey Robert stayed in the case to assist Remington in 3-4 months of pretrial
2 and trials. A very smart decision for Farmers but which had mostly detrimental value to Remington
3 in that he was left alone confronting a corrupt RICO enterprise in a series of jury trials where all
4 the Gans defendants witnesses were effectively corruptly bribed to perjure their material
5 testimony.
6 Allied withdrew their frivolous, fraud-based lawsuit, to pay-off the Mathsons for their
7 loyalty and perjury, allowing the Mathsons to regain their worthless inadvertently fenced-in land,
8 and also allowing Farmers and Remington to avoid the certainty of another $100,000 of wasted
9 litigation costs and the specter of punitive damages, if defendants kept pushing their fraudulent,
10 retaliatory, diversionary suit. Space does not reasonably permit writing 4 pages about it here, but we
11 WILL as needed. Gans and Allied made a believable case with their perjured witnesses, and
12 unethical defense wherein they BLAMED Remington for all contamination on both sites and made
13 it stick due to bad faith subterfuge, unethical advocacy, bad photographs by Mathson,
14 ridiculously inadequate special jury instructions, a simple, an unaesthetic (UGLY) but good-faith,
15 solid fence built slightly off line, and a huge series of pretrial and trial evidentiary rulings so
16 prejudiced and conclusively detrimental to Remington that he inescapably concluded that the judge
17 was in alterably biased or somehow otherwise corrupted. When that above unfortunate fence issue
18 was discovered, Remington attempted to resolve and settle the issue honestly and properly for years
19 and quickly by 2009 had agreed to remove said agreed fence back to the Pulley line, as soon as
20 possible, which has NOT yet occurred.
21 More on this and ALL the improperly explained issues will be added in the federal FAC here,
22 since all money received by defendants and spent for years is believed to be subject to federal
23 penalties now, even Mathsons 2016 settlement money extorted (above) by Gans illicit defensive
24 tactics and paid under duress by Remingtons liability carrier Farmers Insurance.
25 As alluded to above, it is clear and reasonable that insurers deal in the world of bribery and
26 extortion, which they call negotiated settlements and mediations. It was just good business for
27 Farmers to throw Remington under the bus as to his Roberts representation (in ALL suits) and
28 consultant, and to save them a different possible $100-300,000 or MORE. Farmers saw, in their
superficial and cursory way, that Gans might possibly corrupt a jury to illegally extract some
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1 gigantic prejudicial run-away verdict, from a nave, old Remington in pro per. Remington was
2 quixotically, bravely, and no-doubt stupidly fighting an unscrupulous unlimited band of 35 rabid
3 RICO WOLVES, and Farmers did not want to participate as a business decision. Obviously a WISE
4 one in retrospect, as attorney Roberts was spared 100 days so far up in Eureka (from Mendocino),
5 with still NO END in sight, and already a clear savings of at least $100,000+ to Farmers.
6 11. 18 USC 1957. Specifically bars property sales and other purchases with laundered
7 dirty money, as above. Here, simply put: Gans, RAO, Olson, Skillings, Randall, BOTH
8 Mathsons, and probably Lawrence and half of the experts and other named and as yet un-named
9 defendants and their soldiers, are KNOWN to have bought RE with their illicit gains, and when
10 time permits we will gain much more information from public sources investigations, like the
11 Building Department (as to Olsons extensive RE empire along Walnut for about a mile over past
12 Ridgewood School). That is the area where Skillings got his house BRIBE, we now assume, for his
13 loyal illegal work and remaining loyal to Olson all these years, but well will look at the financials.
14 12. 18 USC 1961-4, et seq. Additional money laundering statute barring the use of illegal
15 unjust profits for investments in other rackets or businesses. ALL named here appear implicated in
16 these violations, because they all made illicit deals and purchases with laundered, corrupt funds
17 from RAO/Mathsons initial crimes and then from the revenues from the rentals and house sales,
18 etc over the years and recently ALL have benefited from the cover-up and hush money exchanged
19 between them and paid to the many soldiers and corrupt witnesses here now.
20 THE KEY TO THIS IS: Defendants in ALL their illegal acts named here were damaging and
21 ultimately effectively destroying a thriving, vital interstate wood products business which averaged
22 about $200,000 per year in sales for many years, then dropped into the $100,000 range as
23 Remington geared down, pursued other products, patents and interests and did less retail from
24 Westgate.
25 Remington lost a HUGE opportunity to sell his entire business to Rick Jagger in 2014-15
26 because of efforts in this lawsuit, opportunities that never reemerged. Also at least $50,000 per year
27 of wholesale and retail burl sales to old customers on the mailing lists was lost in defending against
28 Gans frivolous collateral estoppel Summary Judgment, etc. Arguably there have been (At least)
over $400,000 of lost wood sales since 2008, as explained in the damages sections, which just
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1 highlights the fact here that defendants have mortally wounded a thriving interstate business and
2 then reinvested their ill-gotten gains in additional racketeering business and equipment like trucks
3 and loaders to maintain that business, presumably damaging OTHERS (we will locate before trial)
4 all over Cutten and beyond. WHO hauled Richard Millers illegal toxic drums to Carlotta, could it
5 have been RAO? Well find-out a lot with some investigatory time.
6 Also, virtually all internet purchases by defendants and especially by Randall who buys HUGE
7 quantities of merchandise out-of-state for himself and his business job, and presumably for RAO,
8 Mathson, et al., are interstate commerce. Most of the associated members of this racketeering
9 enterprise are small businesses which buy in interstate commerce so on all sides of the equation and
10 these relationships there was criminally derived hush money, illicit sales, continuing elicit
11 controlled substance sales and extortion, etc. In essence, much of the money being used BY
12 defendants in interstate commerce was in violation of 1961-4, but several years of additional
13 discovery will be needed to specify and to prove all details alleged herein, and to provide sufficient
14 evidence to convict defendants on most of these allegations.
15 13. 49 USC 5101, et seq, ( 5000a-5103a-5108-5117). Improper safety permitting and
16 placarding for hauling hazardous wastes. RAOs unlawful hauling in 1998-2000+ is covered
17 elsewhere in the illegal environmental allegations, especially under state laws, CHP Codes and Cal-
18 Trans regulations, obviously all violated since RAO operated clandestinely, illegally and secretly,
19 hauling very early and very late and understanding where CHP patrols and scales were and
20 knowing various local officers personally, etc.
21 THIS predicate federal act occurred in 2015-2016 when John Mathson is seen on surveillance
22 video removing asbestos pipes from Remingtons land, dropping them over the fence and then
23 acting like a human conveyor belt line with himself, moving said heavy hazardous objects a few
24 feet at a time, through his back locked gate and into his yard where he stockpiles debris for a few
25 weeks, until he puts them in his local pick-up garbage can or makes dump runs himself with his
26 garbage trailer pulled by his pick-up. This entire process was very illegal, but the above cited
27 5101 federal predicate act violation specifically refers to the illegal hauling on the highway of the
28 illegally removed asbestos and other hazardous wastes, which Mathson transported without proper
permits.
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1 Being a clandestine, secret, illegal, evidence spoiling and hazardous materials HAULING
2 operation John Mathson gets few permits to do anything and disobeys all relevant federal and state
3 laws, in all areas, as he chooses. For example, when his septic permit for a second backyard sewer
4 system was flatly denied by the county in about 2004, Mathson was undaunted and promptly built a
5 $5-7000 gigantic illegal septic system anyway, complete with tank and lines etc. now the Mathsons
6 have a very dangerous, unlawful health hazard in their backyard which oozes poison E. coli and
7 coliform down onto Remingtons property, especially whenever it rains.
8 14. 15 USC 2607, 2614-15 and 2642. Additional violations of many important
9 hazardous materials hauling laws, by Mathson, Skillings, Kishpaugh, Randall and others, in
10 2014-16, according to additional discovered proofs. As above, surveillance video has proven that
11 John Mathson and others here continue to violate the hazardous wastes hauling laws for asbestos,
12 lead, PCBs, zinc, hydrocarbons and other cited toxins dumped here, as seen on surveillance videos
13 from 2015-16, and to date.
14 See also 40 CFR 763 for same types of provable violations, including those by RAO, the City
15 of Eureka Public Works Department (under control of Boyd Davis from 1996-2000), and in 2015-
16 16 by Randall, Kishpaugh, Evans, Hilfiker, Mathson and others, several of whom have
17 continuously clandestinely DUMPED debris onto Remingtons land in recent years.
18 15. 42 USC 1983, Miscellaneous actionable deprivations of Remingtons rights by
19 defendants Gans and both Mathsons, and others to be specified after further discovery proofs.
20 Examples would include, without limitation: Brisso blocking County Health Department and
21 CA Water Board positive action on Remingtons land and promoting bogus and bribed activity
22 favorable to Mathson such as Eskos controversial letter report and purported extortive testimony
23 which has never occurred and likely NEVER will, according to Remingtons witnesses; Mathsons
24 continued continuous COMPLAINTS to every possible level of government, from County to state
25 about everything Remington DOES or fails to do, from burning to weeds and debris removal to hedge
26 control. This harassment has continued since 2008, and herein Remington can only complain of
27 damages and acts occurring within the prior 4 years, but which in this case started long before that.
28 The file room felonies of tampering with state Superior Court filed documents in a systematic
and continuing manner, were especially egregious and specifically describable in December 2014-
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1 February 2015 while Remington was especially busy, frantically filing long well-indexed and
2 collated documents, and then very ILL from January to about April 2015 and unable to effectively
3 and energetically get totally to the bottom of these crimes. All levels of the Court administration
4 and several judges were involved but nobody really cared about what happens to a hated pro pers
5 long documents and justice has never been done. Note also the above recent complaints about the
6 November 15, 2016 status conference report which has never been sent to Remington as ordered by
7 the court, and probably never will be sent to him.
8 A formal DA investigation could still solve most of these crimes, if Brisso would allow that
9 which is extremely unlikely, some of which crimes are continuing since 2008, as how many clerks
10 have been there THAT LONG, would be a good investigatory start, plus the discussions above and
11 plus a thorough interrogation of the two subsidiary non-named (presently) defendants, discussed
12 above, who were implicated in the file room a few years ago, until discovery reveals slightly better
13 evidence than what we now have.
14 Additionally, the recent (above) $20,000 costs to Farmers, Remingtons insurer can only raise
15 Remingtons rates over time, and Gans prejudicial extorted money from Farmers, as discussed, was
16 actually very beneficial and SMART for Farmers, who wanted to escape financially. Smart for
17 farmers to abandon Remingtons related defenses assisted by Harvey Roberts, but thats business
18 and Remington continues as before.
19 Thats what Gans wanted, his RICO plans prevailed on this issue and cleverly bought-off and/or
20 BRIBED the Mathsons with $20,000 they desperately needed, while getting rid of Remingtons
21 legal lifeline in the process. This was an illicit quid pro quo masterminded by Gans, but arguably
22 perfectly legal and legitimate for the insurers, the enterprise and EVERYONE except Remington,
23 actually. Remington had no choice and was coerced into agreeing to that settlement, as was made
24 clear by Roberts and others at the time. Farmers could be considered complicit in Gans RICO
25 enterprise also, on this issue, since they benefited financially in that quid pro quo, as did Gans,
26 Mathson, and Allied, all at Remingtons financial and emotional expense, however thats business
27 and insurance. Therefore, Farmers is not yet named in this suit, and likely will NEVER be, as the
28 enterprise has to end somewhere and Roberts appeared to always be outside it, whereas Farmers
position was ambivalent and a grey area, ever since 2008. Exactly who did what in the
352
1 negotiations with Gans in February and March 2016 has yet to be determined, and probably never
2 will be, except through a Gans deposition.
3 As above, Judge Reinholtsen is believed to probably be compromised by or at least HIGHLY
4 under the influence of the unethical and criminals Brisso and Gans, but that will be hard to
5 PROVE. NOR does that alone PROVE that Reinholtsen is in Brissos pocket like all
6 Corleones NYC judges were reputed to be, so likely we will continue slowly in state court until
7 Reinholtsens imminent retirement or firing by the state, whichever occurs first.
8 Remingtons eventual preference, which likely is worth NOTHING, and his next state motion
9 will be to STAY all state activity during early 2017 pending results HERE, on all state pendant
10 allegations. Then a decision there may be from THIS Court, as Judge Reinholtsen is overwhelmed
11 in Department 8 and does really not need or want this case there, and hopefully he will determine
12 that on his own. But, if not he will continue to be the judge here in one of these cases. He must have
13 hundreds of cases, An overwhelming caseload, and he is always FAR BEHIND in his cases as his
14 speed and capability is inferentially diminished with age, after observing same for more than 110
15 consecutive 3 hour 2016 hearings, like Remingtons is also diminished, at age 75. Theres no shame
16 in that, and it is inevitable and difficult to overcome.
17 As explained elsewhere, Remingtons substantive and procedural due process rights have been
18 compromised and his bodily integrity and health have been nearly destroyed by Mathsons escaping
19 toxins as they reach the grounds surface and most are invisible to the naked eye, such as 60%
20 asbestos Chrysotile fragments, benzene vapors, carcinogenic silica dust and infectious bacteria
21 which have caused pneumonia and severely debilitating weakness exposing Remingtons body to
22 deadly pathogens such as shingles virus, and related Ramsey-Hunt syndrome immune response
23 causes.
24 Finally Gans has deprived Remington of his legitimate rights to due process in Humboldt
25 superior Court in numerous ways including, without restriction: Plagiarizing a Federal judge and
26 causing Remington to spend hundreds of pages refuting that and related mail frauds; Gans has
27 prevented the due administration of justice to Remington in 2016 pretrial proceedings with his
28 own frequent perjury on material issues, including the twin pipes issue (provably SOLID, but he
and all his lying defendant witnesses swear they are perforated); in motion documents over what
353
1 damages are recoverable under continuing nuisance (he and Plotz say loss of use ONLY when
2 all authoritative Supreme Court cases dictate PLUS remediation costs, if reasonable, to a JURY.
3 Gans and Plotz in general omit, mischaracterize and misrepresent the law to Judge Reinholtsen,
4 who rarely as the time or interest to researches much of it himself; Gans also misrepresents the law
5 as to Remingtons rights under Mangini I & II, etc. to DECLARE either a permanent or
6 continuing nuisance by or AT trial, based on what the remediation proofs show, whereas Gans is
7 still trying to BIND Remington to conjectural, alternative possibility statements made 8 years ago
8 about possible permanence, many, many years ago and before much of anything was known
9 about the contaminated dumps, and long before any contamination studies, volume or remediation
10 facts were known or bids were completed; also the collateral estoppel arguments from Plotz and
11 Gans are wrong, incompetent and do not reflect federal or state law, but they tricked the Court here
12 into subscribing to their viewpoint now requiring a long expense appeals process to rectify the
13 obvious, which Judge Reinholtsen agreed to twice before being tricked or bribed into changing his
14 mind. WHICH, we do NOT yet know and may NEVER know until someone confesses to avoid
15 prison.
16 16. 42 USC 102, SELLING CONTROLLED SUBSTANCES.
17 As explained herein, the Mathsons and the Kishpaughs live almost directly across the street
18 from each other and for several years have had some sort of a drug trafficking operation going-on
19 according to neighbors reports who have seen it, or joined-in, and from what Remington has
20 observed. This drug, and especially amphetamine issue, was a more serious problem back in the
21 mid-2000s, when the MD Tree services guy was still living there across from the Mathsons, but
22 has continued to this day.
Remington has never paid a lot of attention to what goes on down in that area about 100-150
23
yards from his gate and main operations, however he has noticed that beginning as drinking
24
buddies and crazed country-band musician wannabes, at one time back in the 80s or 90s, there
25
has always been considerable illicit and strange activity going on around there, especially lately
26
when the Kishpaughs are in desperate need of money because their house was recently foreclosed.
27 More discovery is needed in this area, and in particular surveillance by the DA and criminal
28 authorities would be appropriate, as Remington is not especially interested in investigating his
neighbors, no matter how hostile, violent or potential threats.

354
However, what is definitely known today from personal observations and unpleasant
1
encounters with Mathson and the MD Tree Services character, especially, that is relevant here is
2
that, beginning in the early 2000s, there were a lot of amphetamines being used and dealt from that
3
triangle of three (3) houses. Around 2000, and for quite a few years while MD Tree Services
4
rented and occupied the house also across the street from the Mathsons diagonally to the north, we
5 had nothing but confusion and problems coming from that area. Although Remington was well-
6 occupied some distance from that area and didnt pay that much attention to it, there were many
7 noticeable nuisances emanating from those three houses, involving loud music, boisterous
8 nighttime drinking and/or drug using laughing and generally inappropriate noisy behavior, plus
9 many strange people coming and going at all hours of the day and late night, that went visible at
10 all, were rather disreputable looking characters, in residential driveway mechanic-types, with loud
on muffled exhaust systems on their old cars, who did not live in that nice residential area.
11
So, MD was the obvious and known amphetamines guy, who no longer lives on this street,
12
and likely is not even alive anymore, and the Kishpaughs were and are still believed to be the
13
marijuana dealer with what appears to be a fairly constant stream of customers remaining today,
14
although Remington doesnt pay a lot of attention.
15 A few years back, Remington was somewhat damaged by all that antisocial behavior which
16 caused some pollution as explained elsewhere is ravine and work your spot just dumped his debris a
17 few feet off the road and into Remingtons hedge; Remington was rather severely intimidated,
18 coerced, extorted and subjected to various psychological pressures for not joining in with these
19 defendants drinking and drug using and because they therefore retaliated by complaining the
20 various authorities about Remingtons nighttime work activities, while they were busy partying.
The amphetamines, marijuana smells and use and the loud music and drinking parties were
21
never an especially big deal back in the 1990s and mid-2000s when Remington was too busy with
22
his own work in relatively noise-proof offices to worry too much about what Mathson, Kishpaugh,
23
Costa, Gary Evans, Hilfiker and Skillings, et al, were up to. The noise and the psychological
24
pressures against Remington for being too much of a worker and not enough of a loose drinker
25 and socializer were about the only emotional damages and/or private nuisance which those events
26 caused Remington four years, and until recently, in 2015-16.
27 Now, the area around defendants houses in the aforementioned triangle has become much
28 more unfriendly, ominous and with the background of the continuous vandalistic extortions and
heavy damage done to all Remingtons business property every week or two, especially in 2016,
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Remington has to pay more attention to primary co-conspirators Mathson and Kishpaugh.
1
Said Mathson and Kishpaugh now frequently stand on their driveway waiting for Remington
2
to arrive at about the same time each afternoon and they attempt to intimidate, extort and make
3
Remington fearful as he gets out of his car, and their enmity and hate is unmistakable and
4
transmitted very strongly from about 150 feet away. Their silent hostile glances basically say: We
5 hate you Remington, we want you outta here, and we will be doing more vandalism and destruction
6 of your property as soon as you go in through your gate to try and work, or otherwise well get you
7 tonight or tomorrow morning at the latest, with a bunch of crude expletives also believed to be in
8 their thoughts. So, as explained throughout, Gans chief tool used today is to distract Remington,
9 make him fearful, of violent retribution and property destruction and generally unable to focus on
10 his work, or to do any productive Burl Tree work to bring in money, making it somewhat difficult
for his family to survive financially, these days.
11
12 5. (b) CHRONOLOGICAL PATTERN OF PREDICATE ACTS
13 from 2012 to 2016+, dates and background, #1-50, next 132 pages:
14 A. Background: In 2007-9, there were early precursors to this RICO action, upsetting as overly
15 aggressive, unethical advocacy, but only California ethical violations that no one seemed especially
16 concerned with. That was LONG before any pattern or racketeering enterprise was noticeably
17 formed.
18 1) Beginning in 2008, Gans and Brisso of the Mitchell firm embezzled funds from their financier
19 Allied Insurance, grossly inflated costs to them and then to Remington when he was billed for
20 swindled costs already paid by Allied. In those 2008-9 special motion fee hearings the Mitchell firm
21 burglarized, over-billed and attempted to extort Remington by more than $9000, but failed in that
22 robbery, when Judge Miles believed Remington briefly and long enough to follow his 20-30
23 pages of proofs which implicated Brisso and Gans;
24 2) Also in September 2008, John Mathson is strongly suspected (and seen nearby) in the actual,
25 serious arson fire at Remingtons 5000 square foot residence under construction, while Remington
26 was simultaneously defending against defendants Special Motion and 40 systematically made
27 organizational complaints, discussed elsewhere;
28 3) In summer 2011, serious defendants experts declaration perjuries and errors in reports-volume,
toxicity, but not yet formalized as perjury at any trial;
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1 4) John Mathsons vandalism pattern was first begun in 2008, but was in its infancy, and easier to
2 contain then, compared to organized, systematic attacks in 2012, ON Figas and Remington;
3 5) Also early threats, anger, extortions and attempts to break Remingtons spirit and that of his
4 experts occurred as early as 2008-11, but not as serious predicate acts then;
5 6) The Mathsons spread untreated feces, urea and associated diseased bacteria and viruses on
6 Remingtons land from their unpermitted, but clandestinely and professionally BUILT illegal
7 septic system since about 2005, again hardly a felonious federal crime, although a serious health
8 threat to Remington and the community, almost KILLING Remington several times already, ETC;
9 B. 2012, Defendants RICO pattern of discrete federal predicate acts began, and continued
10 open-ended continuity, through today, in November 2016 (in approximate chronological order):
11 1. Attempted Extortion by 100+ acts of Mathson & Skillings felony vandalism and burglary
12 over many years, and specifically complained of here from December 2012- December 2016.
13 John Mathsons fully documented and many times complained-of-in-writing Burglaries of
14 burl, iron, mill and agricultural machinery, tools, supplies and equipment, PLUS his exasperating
15 and very damaging serial vandalisms of Remingtons mile long perimeter fences, nursery plants,
16 ALL Remingtons major gardens, miles of irrigation lines, dozen pumps and four (4) major elevated
17 irrigation reservoirs, and Mathsons personal leadership of his often-documented and photographed,
18 tame and trained deer armies, VIOLATE 1951, the Hobbs Act in the many ways described
19 herein.
20 After many years of actually inflicting serious damage to Remingtons property, Gans threat is
21 more than reasonable and has repeatedly been carried-out with obvious criminal and extortive
22 intent. Most federal courts in the United States have determined that there is no need for an overt
23 act to carry out the threat, and no necessity for Remington to permanently give up his land and
24 move from the area in order for him to prove that he has been extorted. The crime of extortion is
25 complete before the money or land is handed over. The laws of extortion are however complex.
26 Remington has in effect surrendered to defendants extortion, for 18 years, as to the area of his
27 property that is encroached upon by defendants dump of approximately 1/3 acre. That area cannot
28 be cleared and remediated today because defendants dumped debris are so deep that it would
totally collapse Mathsons entire upper property, along with his house, enormous garage and all its
357
1 other expensive structures and gardens, if Remington removed defendants contaminants before a
2 retaining wall was built, at Mathsons expense. Defendants contaminants occupy, ruin and totally
3 preempt and prevent any and all fruitful uses by Remington of the area encroached upon by
4 defendants hazardous wastes, leach deadly biological pathogens into the hillside, which have made
5 Remington deathly ill repeatedly, since 2013, and also tremendously diminishes the value of
6 Remingtons entire property. The net effect of the above is that Remington has to date, and for 18
7 years now, been successfully extorted out of a significant portion of the property in dispute in these
8 lawsuits.
9 However there are several other sections of Burl Tree property, the other 2 acres here,
10 involved here, where defendants have not yet been fully successful because Remington is still
11 litigating the basic contamination issues.
12 It is difficult for an outsider or distant court to really understand whats going-on here, hence
13 Remington has provided a large amount of photographs in Volume III, and next will provide an
14 excellent analogy at this point.
15 Consider the Putin and Russian invasion, take over and annexation of the Crimea, Ukraine in
16 2014, which was a criminal land-grab no worse than what defendants did here in 1998 and have
17 been attempting to cover up and justify ever since. Cursorily summarizing tens of thousands of
18 pages about both incidents:
19 RUSSIA:
20 1. Invaded the Ukraine without direct provocation in 2014 and annexed the Crimea, 10,000
21 beautiful and strategic square miles, with an important naval base, and which originally comprised
22 about 1/20 of Ukraine;
23 2. Russia then continued battling, attacking and killing innocent people in the Ukraine, applying
24 unbearable military pressure, threatening to conquer Eastern Ukraine and perhaps all of Ukraine;
25 3. Rather than simply pay rent for a naval base at Sevastopol or in the Crimea, or purchase what
26 they needed, plus access into it, Putin, et al just stole it all free, at the cost of a few score soldiers;
27 4. Today, Putins settlement is simple and effective and analogous to Gans in our cases 1) Accept
28 the status quo; 2) Learn to like it; 3) Dont expect any money from us because were going to spare
your lives; 4) You benefit overall from this transaction because although we are stealing about 1/20
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1 of the best portion of your entire country, you will not be killed because we will stop our aggression
2 and return. To Remington, that is about as pure a form of racketeering extortion, which is
3 contemporary and well-known to all, as one could possibly find out there.
4 Analogously, WHAT GANS HAS DONE HERE IS VERY SIMILAR:
5 1. Beginning in 1998, Mathson and RAO invaded the Burl Trees land and took more than 1/3 acre
6 of its best land, which was proportionately double the size of the stolen Crimea area, in proportion
7 to the Burl Trees overall area;
8 2. For many years thereafter, Mathson and RAO, who are now controlled by Gans, continued
9 fighting, terrorizing and extorting Remington, by killing more than $100,000 of his rarest prize
10 plants, appropriated all his time and energies, and prevented any of his plans from being fulfilled
11 for many years;
12 3. Rather than honestly pay rent on or purchase the crucial land that defendants had annexed
13 adjacent to their backyard, they just took it free, laughed at Remington and proceeded to torture and
14 injure him for the last 10 years now wall Remington attempts to remediate and recover his land;
15 4. Very similar to Putins, Gans extortive settlement proposes that the entirely unacceptable status
16 quo become permanent. They propose: 1) We will keep all of your land free, which we now occupy
17 or have contaminated all the way down the mountain; 2) We do not buy the land, pay no present or
18 back rent and offer no reparations for any of the hundreds of thousands of dollars of various
19 physical damages to Remington, his land into his business, nor is there any offer to clean up the
20 contamination which now has prevented the marketing or sale of Remingtons entire estate. 3)
21 Finally, like Putin, all Gans offers from his side is that he agrees to stop his war on Remington and
22 the Burl Tree, disarm and call-off his destructive soldiers, and then not bill Remington for his
23 (Gans) damages, expenses and irritation in launching and maintaining his aggressive war in the
24 first place.
25 That bad extortive offer from Gans is unacceptable to Remington, and unquestionably if
26 Ukraine could file a RICO lawsuit or had any kind of legally forcible lawsuit against the major,
27 aggressive, treaty-breaking, nuclear BOMB wielding Russians, they would do so, because neither
28 situation is tenable or just in a civilized world.

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1 Since Remington has not YET fully surrendered parts of, if any of his, encroached land or
2 dropped his lawsuits yet, perhaps arguably, the defendants crime of ultimate and completed
3 EXTORTION itself, and their consummating the total annexation of and the taking total dominion
4 over Remingtons entire property and all of the subjects of these lawsuits, may not yet be fully
5 legally complete and prosecutable. Obviously, the complexities, subtleties and intricacies of
6 California federal extortion law case precedents will come into play here. Presumably at the
7 imminent dismissal stage, said detailed California extortion-applicable real estate law precedents
8 will be exhaustively researched and documented, and at which time Remington will more fully
9 explain how Gans extortion is specifically applicable here, and how it has damaged the Burl Tree.
10 In any case, however, ATTEMPTED Extortion, under PC 518 with wobbler sentencing prescribed
11 under CALCRIM 1830, et seq, 1A, and PC 524, IS obviously fully and statutorily complete already.
12 As extensively complained throughout these documents, Gans, Mathson and their associated
13 soldiers variously described above, have unlawfully ruined, destroyed and VANDALIZED
14 Remingtons property for years and said soldiers have threatened to and actually CONTINUED
15 to do that above described vandalism, through December, 2016. The damaging crimes continue and
16 all future and daily threats remain, as complained, implicitly until Remington renounces all his
17 continuing lawful attempts to clean-up and recover his ruined and encroached-upon land, now
18 actually still HELD by Mathson and Gans enterprise generally.
19 By November 2012, John Mathsons extortion pattern had increased in magnitude and
20 frequency to at least once a week and has continued at that level since then. See Remingtons
21 documentations by date, location and severity, from about 2008, and in detail from 2012 to present,
22 contained herein.
23 Recent 2016 video, from increased surveillance cameras, prove Mathson is letting deer, bear,
24 humans and other detrimental animals plus various human forces into and through Remingtons
25 fortress-like security systems, and virtually impenetrable fences (without destructive vandalism)
26 almost daily, since becoming re-emboldened in August 2016, causing renewed HUGE damages,
27 according to trial proofs.
28 As part of that coercive intimidation and worse, Remingtons parked pick-up truck has been
repeatedly vandalized and sabotaged in his driveway (as the Mathsons have previously called it
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1 ugly and misrepresented it to governmental authorities as part of Remingtons junk yard) and
2 also his basic transportation car has been tampered with in the public street in front of his house;
3 THOSE documented and photographed criminal racketeering acts by Gans soldiers, Mathson,
4 Skillings, Costa, Randall, Hilfiker, Kishpaugh, etc., especially are the enterprises primary extortion
5 scheme to DRIVE Remington from his land, harm that land and development, and further and
6 completely destroy the Burl Trees inventory, building, fixtures, gardens and all business
7 development here, which is everything located at 832 Westgate Drive, the property at issue here;
8 2. John Mathsons intimidation and extortion of expert Mike Foget, violating 18 USC
9 1951, 1503, 1512-13, occurring twice, in summer and winter 2012-13, during Fogets initial
10 engineering visits here in 2012-13. In 2012, John Mathson jumped-out from behind a redwood tree,
11 scaring Foget and Remington, and like an insane jihadist suicide bomber yelled serious intimidating
12 threats at us, exhibited crazed, unpredictable and volatile anger, simulated 3-4 silenced rifle shots
13 with a flash camera, before we even knew what was happening, and then threatened us with
14 potential great bodily harm if we did not immediately run away from the area, and overall exhibited
15 frightening irrationality and out of character unpredictability;
16 3. Specific Felony sabotage vandalism by Mathson. Remingtons main 8500 gallon irrigation
17 Tank A was severely sabotaged by John Mathson, with a heavy 8-foot long, well-sharpened
18 redwood branch spear, on a known 2013 date in everyones records. Humboldt County sheriffs
19 were called-in for this felony mischief, which also involved several signs posted by Remington and
20 Mathsons multiple invasions of Remingtons property to manipulate those signs, etc. A Humboldt
21 County Sheriffs deputy investigated these multiple incidents and interviewed both Mathsons, but
22 since both lie well and did so in this case, denying everything. That issue has not been yet covered
23 in any sworn trial testimony, but when it is, at the first relevant trial opportunity, we will prove
24 additional Mathson perjury.
25 Many other details exist of this episode, where signs were posted and manipulated by Mathson
26 who enters Remingtons well-fenced yard at will through an elaborate (Not so secret anymore)
27 secret door Mathson originally, clearly with criminal intent, built into his solid 8 fence in about
28 2008, PROVING his malicious, long-term sabotaging and felonious intentions SINCE that time.
These felony incidents, which caused damages well in excess of $500, violate 18 USC 1951 and
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1 also 1512, and are an attempt to intimidate star witness Bruce Remington and make him too
2 fearful to leave his property or to testify against the Mathsons or any of their criminal enterprise
3 conspirators.
4 4. Malicious mischief violating 18 USC 1951, 1512, 1503 and 1512 (involving
5 PROMINENT expert and witness Bob Figas). In late November 2012, John Mathson was caught:
6 snooping around Remingtons entry gate26, 4 hours after dark; leaving Remingtons yard hurriedly;
7 leaving Remingtons Burl Tree gate unlatched (and unsecured), as he studied Figas loader to
8 determine whether the key was in it and how to vandalize or BURN it, according to proofs. If the
9 key was in a 100,00-pound excavator, Mathson could have done grave damage to Remingtons
10 entire structure and property. Remington fortunately (and luckily) caught him in the act, before we
11 had live security cameras set-up everywhere, while Remington unexpectedly was going to get
12 something from his car about 10 PM. There were several similar and related repetitions of these
13 Mathson and Skillings reconnaissance like missions, in order to plan criminal racketeering acts,
14 which also extended into late December 2012, and early January 2013;
15 5. Were going to KILL you! ( 1951, 1503 and 42 USC 1983 violations). In December
16 2012-about mid-2015, John Mathson always circled Remingtons entire property perimeter,
17 virtually every day, more than one mile of steep terrain by Mathsons route. Mathsons work was
18 to take many pictures, look for animals and their trails in terms of Remingtons fence vulnerabilities
19 and the best places to penetrate his fences where discovery would be the most difficult, and to stare-
20 down, yell or inaudibly mouth obscenities, threats and generally to harass and/or threaten
21 Remington frequently and approximately once daily, if possible. Mathson knew intimately the local
22 deers feeding habits, schedules and also Remingtons work pattern, on-going projects, which part
23 of the yard he was likely to be working in, and his usual arrival times, all very precisely.
24 Virtually every day, Mathson would WAITFor Remingtons car to arrive and then LOOK for
25 Remington working thereafter, posture, try to look menacing and confident, attempt to
26 intimidate and rudely and brazenly stare down Remington in daylight, as he circled Remingtons
27 entire property, at least once DAILY. Mathson is really a coward and therefore does at least 99% of
28 26
As Explained several times elsewhere on March 6-8, John Mathson seriously tampered with
Remingtons front gate on three consecutive nights, and finally we got that on surveillance video for the
trial. Is about time!
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1 his criminal dirty-work in the very early morning hours and until about 10 AM, because Mathson
2 well-knows that Remington has essentially never, ever arrived on the property before 12 noon and
3 usually not until much later than that, unless he was sleeping there which he does fairly frequently.
4 After several years, when the circling, staring and photographs were very ineffective, and did
5 not really work AT ALL, Gans and/or Joy Mathson must have suggested that John Mathson up his
6 game to SERIOUSLY force the hated Remington to pay-attention to John Mathsons territorial
7 strutting, posturing, adolescent attempts to assert his dominancy and ominous often silent glares
8 and generally inaudibly muttered threats. However, on or about January 17-8, 2013, according to
9 business records, while Mathson was walking along Westgate Drive by Remingtons prominent
10 front gate, while he was fixing it (AGAIN), Mathson coldly and rudely stared at Remington, and
11 without ever breaking stride or attracting any particular attention to himself, he softly mouthed, so
12 no neighbors friendly to Remington could hear:
13 Were going to kill you, motha fucker, or indistinct words to that effect, from only about
14 20 away.
15 John Mathson attacks and damages Remingtons front gate more than any other single area,
16 [SEE Also footnote 26 above] because it at least at one time seemed so unlikely, was so frequently
17 used, well-patrolled to the point of complacency, somewhat porous and vulnerable. For example
18 in two of Mathsons latest acts of vandalism (as these documents were being written over several
19 months): On November 15, 2016 he removed interior fencing on the Cooksey-side 20 tall x15
20 thick privet hedge and cleared a deer path, which Remington discovered that evening and repaired.
21 Then, early the morning of November 16th Mathson again ATTACKED Remingtons heavy,
22 commercial gauged galvanized pipe and chain-link fence gate at two different vulnerable points,
23 actually bending several metal support frames with a crowbar or similar leveraging device, enough
24 to allow deer to enter and also he removed a vertical bar which was blocking a 12-16 inch wide gap
25 large enough for a deer to squeeze through, at the latching and locking portion of the gate which
26 opens about 2 to allow human entry. Without writing the detail of a patent application, in other
27 words, the portion of the 10-foot wide gate opposite to where it is hinged, and where it is opened
28 about 2 feet and wide enough for a human to enter and then close it, there was an opening just wide
enough for a deer to squeeze through after mass and removed the iron bar which went right down
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1 the middle of the approximately 14-inch wide opening, which existed under normal gait latching
2 conditions.
3 Remington noticed, found and REPAIRED WELL, all 3 deer openings (or where even a
4 skinny human might possibly attempt to crawl through) described above, and took 9 photos of all 3
5
6 openings for clarification, discussion and possible uses at a RICO or other future TRIAL.
7 6. Major, damaging 1951 and 1512-13 successful extortion, blackmail, harassment,
8 coercion and intimidation of central Remington expert remediation and engineering contractor
9 WITNESS Bob Figas, an IMPORTANT early, specific series of predicate RICO acts, in this case.
10 Beginning in December 2012, and escalating in intensity, severity and effectiveness in 2013, in
11 coordination with John Mathsons continuous updates to Gans about all Remingtons activities on
12 the properties, both Skillings and Rich Olson directly, intentionally, actionably, and independently
13 (witnessed) intimidated, coerced and actually successfully extorted and blackmailed Bob Figas.
14 This series of at least 3 phone calls and possibly one visit, promised immediate severe physical
15 retaliations to or AGAINST Figas, his equipment, business and or possibly also on his shops,
16 equipment storage yards and buildings. All details of these very extortive and damaging predicate
17 acts will be discovered MUCH further, because Figas has been reticent or afraid to freely discuss
18 these severe coercive threats, since all of defendants threats STILL FULLY APPLY today. These
19 early 2013 extortive threats were also just the beginning of a series of additional threats made to
20 Figas over the next several months until May 2013, and until Remington stop trying to get Figas to
21 do any further work on the Burl Trees land, for a while.
22 THIS is a central and very important RICO predicate act because it directly, provably and
23 dramatically DAMAGED the Burl Tree in MANY different ways, as explained below:
24 1) Remington and the business permanently lost sales in Portland, Oregon, for: significant
25 tonnage of structural scrap iron, hydraulic sawmill power and control units, large 3-phase motors,
26 saw mill machinery (operating forklift, Silverado pick-up with crane, mill feed and shop work
27 tables, 26 x 10 band saw blades sales, and extensive 3-phase wiring and electrical boxes, ETC.
28 Figas was scheduled to load, remove and haul all that to Oregon, not 3 days after he abruptly
removed his 90,000+ pound excavator and ran away like a scared rabbit;
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1 2) A substantial and critical portion of foundational land which supports the 50 tall, 8000 square
2 foot residential, working offices and storage facility for Remington and the Burl Tree, collapsed and
3 dropped 6 in a major slide only 2 months after Figas abruptly removed his excavator (after hauling
4 away Remingtons 80,000# loader). The slide occurred BECAUSE Figas left 3 deep gashes in the
5 road which became rivers which rushed into the 5 deep chasm and indentations left from the loader
6 removal job. In short, Figas failed to do the most basic or ANY obvious winterizing of the site
7 when he unexpectedly and abruptly left without regards for anything except his own safety. HOW
8 and exactly why that shocking set of circumstances occurred and how a mature, stable, very nice
9 and responsible 30-year friend of Remingtons could be frightened so much and so fast, still
10 remains to be probed IN DEPTH in this proceeding, under oath from ALL INVOLVED;
11 3) Additionally, Burl Tree property (as above has further deteriorated, water and electrical lines
12 were removed and damaged at that time in 2012) was damaged and inventory was damaged when
13 the detailed 2012 plans involving burl sorting, iron and machinery sorting and re-piling and
14 covering, etc were NOT executed as scheduled. Thereafter, Figas claimed he was again ok with
15 all this, and presumably had gotten over the Gans ordered RAO coercion and extortion threats and
16 would return in March, and then May. However, Figas apparently did not get over his fear as
17 quickly as he had anticipated, or it was renewed frequently, according to discovered proofs. Now, It
18 seems likely that Figas may never be able to work here again or at least until all litigation is 100%
19 completed and Gans and/or RAO give him an okay to work here. Simply put, this is just a standard
20 protection racket and Figas has been told that he very definitely needs protection from Gans
21 enterprise, or he will suffer drastic consequences of some kind. Meanwhile, even in late 2015 and
22 until June 2016, clearly Figas KNOWN FEAR, intimidation, extortion and coercion, ETC. has
23 continued and escalated, because Figas has been entirely afraid to do any more work here. The
24 precise, words, terms and/or conditions of the blackmail have yet to be investigated in Discovery,
25 and whether Figas has the guts or motivation to stand-up to possible cold-blooded, psychopathic
26 killers like Olson, Skillings, Mathson, et al is unknown. Without criminal authority, such as the
27 district attorney or FBI, involvement, Figas may be unwilling to ever risk his life, working career
28 and million+ dollars of equipment backing an old pro per in the face of such potentially VIOLENT

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1 forces, without SERIOUS PROTECTION. What that protection can be at this point is a little
2 hard to imagine;
3 4) Today, much of the Burl Trees inventory described above, the scrap iron, mill machinery,
4 business inventory and property above is now inaccessible or depreciated in value. The price of
5 scrap iron and machinery is diminished by almost 50% from 2011-12 levels. Significant profits in
6 the $125,000 range have been lost permanently just in the above described items alone, and the
7 slide above could eventually cause as much as $500,000 of damage if it remains increasingly
8 unstable.
9 TODAY, said slide appears stabilized and has been massively planted with tons of foliage and
10 roots, but a major earthquake now could REALLY destabilize the houses massive 150+ ton
11 concrete foundations, which are all directly attributable to Skillings removal of Figas in mid-
12 project, in mid-winter, when no contingent mitigation measures were possible;
13 5) Finally, Burl Tree profits were directly and hugely impacted by lost wholesale deals mostly
14 derived from the Rick Jagger Colorado connection in 2013-14, is described extensively elsewhere.
15 Also, the lost time of Remington, its operating executive, CEO, chief production worker, owner,
16 sales manager, builder, burl cutter, finisher, driver, operator, packer, administrator, wholesale and
17 retail salesman and trouble shooting mechanic. The financial losses and case authority for
18 attributing lost profits to lost time involved, in necessarily defending against and combating
19 frivolous litigation will be presented in subsequent federal motion forums, herein and in state court.
20 In summary: RAO made believable, credible phoned and in-person threats to Figas that they
21 would destroy his excavator, his business, reveal Figas darkest secrets, and possibly worse if he did
22 any excavating at all on Remingtons land in 2012. That was how Figas characterized the situation
23 to Remington in 2-12-13; HOWEVER, subsequent odd Figas behavior and multiple broken
24 promises, most recently concluded in 2015 with Figas suggestions and his URGING to find
25 someone else (i.e. Wayne Marsh and his brother) to do Remingtons $200,000 of needed work
26 proves this extortion goes VERY deep and is SERIOUS.
27 Inferentially, until the RAO and Gans Enterprises threateners are safely in prison, Figas
28 appears to have ORDERS, that he is deathly afraid to disobey, to stay-off Remingtons land and not
do any DIGGING which would reveal skeletons, felony hazardous wastes dumping crimes and
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1 other, presently unknown very dark SECRETS, obviously. Otherwise why bother Figas and
2 Remington? The thought definitely occurs, and reoccurs: What did RAO, Mathson and Gans do or
3 bury on these contaminated, hazardous dumpsites that was criminal or evil enough to threaten
4 felonies, arson, extortion, black mail, severe bodily injury and possibly murder against anyone,
5 including Remington, Figas and Marsh to date, that might innocently dig up their secrets?
6 Obviously, those secrets are really big and really important to defendants and their MYSTERY
7 certainly arouses HUGE curiosity, so that we will absolutely dig-them-up and see what they are, as
8 soon as possible. So far, defendants have made no less than ultimate attempts to avoid detection of
9 whatever they have buried here, which inferentially must be at least radioactive and biological
10 wastes, with felony imprisonment penalties, plus more than one dead body to justify the grave
11 concern defendants have about us excavating anywhere near the dumpsite, let alone in the
12 residential toxic waste dump, itself.
13 7. Based on and in addition to the above, Remington herein asserts at least THREE (3)
14 additional counts of specific, serious, criminal, escalating 2012-13 ACTS of 1951 extortion,
15 intimidating and misleading conduct, obstructing an important expert and fact witness in
16 state and federal proceedings, plus retaliating against, threatening, bribing and/or improperly
17 coercing a witness in a proceeding related to the commission or possible commission of a federal
18 offense.
19 Specifically, in January-February and inferentially at least once more in approximately May
20 2013, additional repeated extortion and related blackmail, threats and intimidations caused Figas to
21 break additional specific promises to Remington. By May 2013 he had changed his position to
22 refusing to return until Olson, Skillings, Mathson and/or Gans permitted it. Initially, in early 2013,
23 Figas just wanted to know about the lawsuit, as THEY threatened him with being sued and
24 having to potentially spend $100,000 on a lawyer if Figas remained with Remington and dug one
25 bucket of dirt or burl on Remingtons land. Remington reassured him, he thought successfully,
26 about that in January 2013, but RAO, Gans and the ENTERPRISE worked on Figas further and
27 again in spring 2013 while Remington was doing other work. Inferentially, the enterprise
28 blackmailed him with something very severe in spring 2013, and inferentially it now appears that
Remington may have lost Figas entirely at that time, in all likelihood.
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1 In fall 2015, when Remington again spoke seriously to Figas about doing some additional
2 excavation work here, Figas mostly just suggested using Wayne Marsh, which is still unfathomable
3 and very surprising, that Figas remains sufficiently coerced and intimidated to give-up a potentially
4 $150,000 excavation job here. Many mysteries remain here involving Figas and defendants grave
5 fears about him or anyone excavating anywhere near that dump, mysteries which we will probe and
6 further discover information about at some upcoming, comprehensive, and very candid depositions;
7 8. More malicious mischief. Not every retaliation, extortion, and/or intimidation attempt to make
8 it easier for Remington to LEAVE than to stay, and fight was a felonious, Federal predicate act.
9 MOST were not, obviously, but Gans enterprises clear message to Remington in recent years
10 has increasingly been to Make Remington an offer that he couldnt refuse. The meaning of
11 that phrase in the context of the several hundred pages should be clear, but because Remington has
12 not yet accepted that offer and has not yet cowered in fear for all of his property, gardens, estate
13 and increasingly worries about his personal safety, Remingtons prosperous, happy and (formerly)
14 healthy life in this neighborhood, has become increasingly in doubt.
15 Gans Enterprises overall hostile, coercive pattern is clear and EVERYTHING Gans ordered
16 Mathson and Skillings to DO advanced their objectives, which as we have described, very clearly
17 are to:
18 A. Avoid all clean-up costs, by defendants or anyone, since they do not want the dump disturbed;
19 B. Avoid criminal prison-time and civil liability for all their 1998 criminal activities;
20 C. COVERING-UP ALL of this, at all costs, using any means necessary including violence;
21 D. Occupy and KEEP Remingtons adjacent land RENT FREE and eventually get it ALL cheap;
22 E. Make exaggerated profits and exorbitant wages for all enterprise members; and
23 F. Crush Remington, no matter what monetary investment or violence that requires.
24 Specifically, in March 2014, Remingtons 8 tall, strong, well-secured fence, near Tank A,
25 along the property line, was plainly broken off a 4 diameter redwood tree by John Mathson about
26 80 from Westgate. ONLY John Mathson has access to that well-secured doubled-fenced-in area
27 behind his house and fenced yard, protected by security cameras and obnoxiously, continuously
28 yapping guard dogs, ALL night long. Mathsons intention was to further damage Remington by
deliberately leaving his wet organic garbage out all night, along with some of his dumb neighbors,
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1 which should know better than to leave garbage cans out all night on the street, and then let bear in
2 to Remingtons fenced-in enclosure to spread serious amounts of garbage from several cans put-out
3 by multiple neighbors. Mathsons destructive scheme was to remove Remingtons fence from its 4
4 diameter redwood tree post, the evening before garbage pick-up day, and then to make it
5 easy, obvious and essentially automatic for a huge bear to grab several garbage cans worth of
6 plastic-bagged garbage and then to carry it through the hole in Remingtons fence to a vast array of
7 perfect picnic areas for a bear in the middle of Remingtons gardens.
8 Very predictably thereafter, 4 very messy cans worth of very nasty putrid, organic and paper
9 trash-ridden garbage were partially eaten, strewn-along several paths, and then scattered over an at
10 least 1000 square feet area in two different adjacent parts of Remingtons property. Whether then
11 wind blown, or perhaps the bear later decided it did not want to eat in such a sloppy picnic area, the
12 final result was a big mess of substantially uneaten garbage and paper trash for several hundreds of
13 feet and far down the mountain, in relatively impassable, rugged brush, amidst Remingtons
14 gardens and paths. Complete cleanup was difficult and required more than one heart our work and
15 4 large 30-50 gallon black plastic bags.
16 9. Penal Code 526 and 527 PC violations. Gans December 2014 plagiarized false quotes of a
17 Federal Judges SJ Orders and dicta and simulation of a Federal Court Summary Judgment
18 ORDER from Judge Vadas, in order to falsely obtain an erroneous and knowingly fraud-
19 based collateral estoppel ORDER against Remington in Judge Reinholtsens state court
20 proceedings, a year later. Gans unethical and criminal fraudulent scheme against Remington and
21 both courts, caused vast legal confusion eventually regarding collateral estoppel, and eventually in
22 2016 Gans finally prevailed with his MIL #20, which eventually should be successfully appealed
23 and overturned. Meanwhile, it was an unethical and lawbreaking act and is complained about
24 above. Eventually, when Judge Reinholtsen had a couple of months to carefully weigh these issues,
25 he became influenced by that and/or possibly by the other inducements postulated, but which will
26 require more very serious discovery from the Mitchell firm, and probably will eventually require
27 at least one Mitchell firm enterprise member to turn-on Gans to save themselves, and in order to
28 avoid prison. There are also other ways to get to a just result regarding Gans fraudulent quote of
the Magistrate, and to what degree Judge Reinholtsen was influenced by that, but we wont
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1 speculate here now and just let natural discovery processes and future developments determine the
2 real truth of the facts herein alleged.
3 Gans fraudulent material plagiarisms of the central issue in the cases, and multiple, unlawful
4 false quotes of a federal judge at state collateral estoppel summary judgment (CE SJ), may not be a
5 federal crime, but appear to be at least state crimes, as defined by PC 526-27. Gans false Federal
6 Judge ORDER simulation certainly ultimately confused and deceived Judge Reinholtsen, mostly
7 because Reinholtsen trusted Gans and Brisso as two highly trusted, revered former law partners and
8 fellow members of the California bar. Said judge also surprisingly (to Remington) still perceives
9 and regards said Mitchell firm partners as ethical officers of the court, which misperception is
10 based-upon the brilliant tricky deceptions and related devices that Gans has cleverly maintained and
11 perpetrated upon said court for many years and continuing still into January 2017. Remington
12 spent many hours of oral hearing time and more than 100 pages of pretrial motions in limine
13 arguing about Gans unethical deception and corruption of the state cases, but as explained above
14 Judge Reinholtsen did not want to hear it, and said that was such anger and authority that
15 Remington understood that he meant it, more so than any other ruling that he made for about eight
16 years. Now we see that Gans is not really an officer of the court but is in reality a corrupt and
17 criminal act are posing as such, but we need a federal judge to also see it, not just a disrespected Pro
18 per.
19 The above transgressions, detailed specifically elsewhere and in 200+-pages in 2014 SJ
20 Oppositions, show Gans ethics, motivation and MAY be considered by this court in evaluating
21 whether a hated pro per can be allowed to go after a clearly corrupt California attorney, and avoid
22 dismissal at the pleading stage, let alone accomplish the unheard of and nearly impossible task of
23 sending a mighty (alleged) officer of the Court to prison and certain disbarment, thereafter.
24 Remington thinks the overall deceitful pattern of a criminal enterprise is obvious in the entire
25 gestalt, and hopefully, this court will agree.
26 Judge Reinholtsen initially denied Collateral Estoppel Summary Judgment, without sufficient
27 understanding of the case law or philosophy and for the WRONG reasons, so eventually when
28 pressed and probably influenced somehow, he apparently forgave and also must have forgotten

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1 Gans criminal, plagiarized writings (above), and also had to lose touch with justice and logic, in
2 Plaintiffs view.
3 10. In January-February 2014, Gans 170.6 disqualification of Judge Miles was not a
4 federal crime, obviously, but in this context that disingenuous removal greatly PREJUDICED
5 Remington and obviated the TRUTH HERE, and was MORE THAN a mere legitimate tactical
6 litigation measure to aggressively represent his client. Gans is REALLY in actuality the client and
7 makes his living off these cases and intends to continue that indefinitely. Gans is the only
8 defendant that can actually make money on this and has already made several hundred thousand
9 dollars, and his reckless and ruthless litigatory style reflects that. Hence, Remington has seen him
10 as the defendant for many years and the Mathsons are kind of a decoy and/or ventriloquists
11 dummy, and nothing more, in Remingtons opinion. Gans specializes in antagonizing and extorting
12 Remington and in effect FANS these litigatory flames, whenever any potential resolution is ever
13 neared and therefore everything he does is intended to add another few YEARS to his endless
14 gravy train of cases and appellate courts.
15 HERE, Judge Miles clearly knew about the Mitchell firms reputation for corruption and bad
16 ethics from her prior work in this case alone, and probably also from numerous other encounters
17 with the likely multiple RICO enterprise(s) operating from the Mitchell firms offices. Remington
18 logically presumes that she clearly remembered the Mitchell firms blatant, unconcealed corruption
19 from her previous analyses of Gans and Brissos inflated special motion attorney fees, billing
20 Remington for dozens of hours spent working on other issues and clients, double-billed Remington
21 for motion fees UNRELATED to the special motions and GROSSLY exaggerated their hours spent,
22 as analyzed above, and summarized in her reduction of their Lodestar fee request by more
23 than 80% overall. In any case, Gans and Brisso clearly remembered Judge Miles, and clearly
24 remembered and believed that she was on to their deceit, deception and corruption, so therefore
25 they peremptorily disqualified her in January 2015. However, there was a very odd timing-factor
26 there. Defendants attorneys knew that she was a threat to them, but did not disqualify her until one
27 day before the hearing, which has always inferred to Remington that probably their courthouse
28 saboteur had seen or heard of a preliminary summary judgment ruling from said Judge Miles which

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1 was negative to Gans, so when they heard that they had lost, Gans then very belatedly elected to
2 roll-the-dice with a different judge. They did so, but lost there also.
3 On the street or here in Remingtons world of ordinary decent, average every-day ethics and
4 reason, the Mitchell firms enterprise leadership are merely extorters, burglars and common street
5 THUGS, but in Humboldt County Superior Court they are still strangely honored and respected as
6 officers of the court even though they really have no clothes on, and have lost all of their
7 former outstanding 20th-century ethics. For some unknown reason, Judge Reinholtsen still
8 considers Gans, Brisso and Plotz to be respectable advocates and almost royalty, which will stop
9 when, or IF, some court LOOKS closely at Gans especially again, just like Judge Miles looked at
10 Gans AND Brisso in 2009, when BOTH, when actually scrutinized, came-up very CROOKED,
11 while muttering like Nixon, Im no crook.
12 Arguably, Gans and Brisso also committed multiple mail frauds in sending the above
13 fraudulent attorney fee documents to Remington and the court, and Remington can identify literally
14 dozens of other Gans mailings involving various degrees of fraudulent issues, mischaracterizations
15 and fraudulent misrepresenting discussions and declarations regarding said fraudulent
16 misrepresentations, false facts an/or deliberate omissions of virtually all just and accurate facts,
17 during an 8-year, so far, materially and ethically fraudulent barrage of documents to Remington and
18 the Courts. Specifically, Remington has designated at least 30 examples of mail fraud alone within
19 these documents and has represented that there will be many more when time permits further
20 searches.
21 As explained above, EVERY document Gans sends is not a mail fraud, but MANY ARE.
22 Many are fully legitimate but at least 30-50% have fraudulent or corrupt purposes and content.
23 HOW many are too many for a California lawyer? Obviously, many are tolerated, allowed and
24 acquiesced to in Humboldt County, especially with a Superior Court judge who is under heavy
25 ethical scrutiny and possible criminal felony indictment himself for ethical frauds and
26 embezzlement. Remington passes no moral judgments here, but must note that it would appear to
27 be hypocritical for a judge under possible (maybe probable) indictment to make conclusive rulings
28 against Gans on very similar, although much worst and more numerous charges.

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1 How many murders or kidnappings are too many? Is one a month too many but one a year is
2 okay?
3 Of perhaps minor relevance, Gans often goes up to 30-days, during stays, lulls or awaiting
4 crucial decisions or appeals without committing any frauds in THIS case. In fact, during those
5 occasional lapsed periods, Gans often goes months without doing anything in these cases but what
6 about in his OTHER cases? When he is doing no work in the Remington cases, it is more than
7 somewhat likely that he is doing fraudulent legal work on behalf of someone else. Other unethical
8 and fraudulent work in other cases and related complaints and/or comments from other unhappy
9 and perhaps criminally defrauded opposing attorneys is actually extremely likely, and that will be
10 exhaustively checked by someone, when time permits.
11 Remington believes that what has happened here in Gans case is that we have a repetitive
12 THIEF, surreal liar, who actually thrives on and loves the seat trickery and deception, but who no
13 longer possesses the intellect to get along competitively in the ethical world by merely using
14 ordinary honest tactics, or possibly we are dealing with a psychopath, at some point, who really
15 cant control himself since all of this got really severe, sometime during 2015.
16 Plainly, candidly, dispassionately and un-maliciously expressed: Remington believes that
17 Gans unethical borderline criminal and flagrantly unlawful, long-time advocacy practices derive
18 from his basic lazy, inept and competent (for this area anyway), but below-average skill as a lawyer;
19 and, therefore when we investigate further, which we will, it is expected that most of Gans
20 adversaries in the last few years will be tempted to file their own RICO actions, and likely be
21 inclined to assist the district attorney and/or FBI in their investigations of the predicate acts alleged
22 herein. Thats just Remingtons present opinion, which will be confirmed or denied in the next
23 several years.
24 11. Specific multiple, related prejudicial instances of 1503 FILE ROOM Obstruction of
25 Justice occurred in December 2013-January 2014, violating Remingtonss due process rights in
26 state court and nearly causing his just cases to be DISMISSED. These felony file room document
27 tampering charges are very serious and are mentioned and emphasized here because of the:
28 magnitude, brazen audacity, clever and prejudicial timing, and because of the large number of
incidents, occurring over an eight year. In other words, there are numerous, serious, prejudicial and
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1 not accidental. It does not take a paranoid genius to determine that a dozen or more felony
2 courthouse document tampering incidents are deliberately caused by somebody with an enormous
3 stake in destroying Remington and dismissing his lawsuits, which in Remingtons opinion leaves
4 only the Mathsons and/or Gans and his Mitchell firm as the demonic master-minds of these
5 crimes.
6 Someone, must be extraordinarily motivated and brazen and/or extremely well-paid to risk up
7 to 20-years in prison for tampering with a few Remington motion documents. Who cares that much
8 about destroying Remingtons lawsuit to risk that degree of imprisonment? Very few people. How
9 can they be so positive they will not be discovered? How much money would be enough to risk 5-
10 10 years in prison, and why would there be that kind of money available here? To Remington it into
11 a lovely would have appeared that until the last year or so there was nowhere near enough money at
12 risk in these cases to risk that kind of imprisonment by any defendants nefarious agent, plus
13 losing a good state courthouse job and being forever stigmatized. Financially, it just does not seem
14 to Remington to make sense to motivate the courthouse saboteur. It would appear that whatever
15 money they are being paid would not be enough or equivalent to their risk, so therefore there must
16 be something very emotional involved for said saboteur.
17 Plus, who is going to pay a courthouse saboteur or mole $100-200,000 to tamper with, shuffle
18 or steal a few of Remingtons documents? Someone, inferentially must be insane in defendants
19 camp, and that to Remington points entirely to ONLY Gans, a Gans relative and at least
20 equally to Joy Mathson and her 2-3 daughters or many others of their local relatives.
21 Courthouse executives were informed of all this and said they would investigate all this several
22 years ago, but obviously it was not done zealously or effectively because said saboteur is still
23 believed to be present in December 2016.
24 This instance described here, as #11, occurred within the statute of limitations, and was one of
25 4-5 instances of the most egregious file room felonies perpetrated upon Remington in these cases.
26 Many of them occurred prior to 2012 and several after that. Tampering with Remingtons
27 documents as described herein in several places always damaged Remington and led to several non-
28 oppositions by Remington, missed filing deadlines for every type of document, not receiving many
court orders or decisions for more than two years on several occasions (when Remingtons name
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1 was prejudicially twice removed from the courts service list) and the untimely filing, and
2 resulting court ignoring of multiple Remington Oppositions and Reply memorandum, including
3 delays in several crucial Summary Judgment Oppositions, as described HERE, in this section.
4 During the Christmas 2013 Summary Judgment proceedings there was general massive
5 confusion, involving last-minute canceled and postponed summary judgment hearing dates and then
6 a very late disqualification of Judge Miles as explained above, which occurred only two days before
7 the scheduled hearing and at least six weeks after Gans had learned that she was determining his
8 collateral estoppel summary judgment motion. In fact, that late disqualification strongly inferred
9 that Gans Courthouse saboteur had seen an adverse tentative ruling from Judge Miles and before it
10 could be further codified at a hearing or made permanent, Gans decided to disqualify her.
11 What is absolutely certain is that The Mitchell firms and/or the still unknown and
12 unapprehended Mathson-related, presumably insane Court house saboteur (discussed above)
13 separated Remingtons major 1200+ page document packets and made Remingtons Oppositions
14 unintelligible in two courts. Hundreds of Remingtons summary judgment opposition pages were
15 scattered all over the courthouse, which Remington discovered about a month after the filing
16 deadline when some file clerk called him on the phone to ask what he wanted done was several
17 hundred purportedly extra pages of his summary judgment opposition documents. The problem,
18 of course, was that Remington filed no extra copies of anything but he did properly file about
19 1500-pages of closely-related and largely identical documents, in two medium-sized boxes with
20 two different judges. It took more than two (2) months to determine that maybe both judges got
21 most of the opposition documents.
22 More than 50-pages have been written and filed, with court executives and judges, about this
23 previously with the state court, so defendants are well-aware of the charges against them, so
24 additional detail is omitted here. Gans clearly has a highly paid, or very motivated and emotionally
25 involved spy in the file room or similar regions of the courthouse, who repeatedly, over many years
26 has masterminded frauds on Remington, tampered with his filings in MANY egregious ways plus
27 related timing, technical and administrative ploys and dirty tricks, all of which GREATLY
28 damaged Remingtonss Burl Tree defense by tens of thousands of dollars, in time, costs, emotional
stress and Harvey Roberts time, which was initially paid by Farmers insurance company but
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1 ultimately Remington expects to bare a considerable portion of Roberts attorneys fees over the
2 next 20 years in increased homeowners insurance costs.
3 12. Count #2 of 1503 FILE ROOM Obstruction of Justice. MANY other related felonious
4 tampering with State civil procedures and justice took place there, e.g. the October-November 2013
5 discovery, more than two years later, that Remington had been deliberately and improperly
6 REMOVED from the Courts service list, since about mid-2011, resulting in Remington not
7 receiving any Court decisions for more than a year, of active court ORDERS and decisions,
8 including several CRUCIAL ones, such as Judge Reinholtsens 2011 SJ decisions and his requests
9 for additional briefing, which Remington never got, never saw and hence NEVER responded to.
10 Not receiving that crucially important summary judgment document and tentative decision
11 eventually became extremely important when Remington spent at least three months in 2015
12 drafting another summary judgment motion, which essentially rendered Remingtons 2015
13 summary judgment motion mostly moot and irrelevant. How much are Remingtons damages in
14 this court system when he wastes a solid 3-4 months of his own time, plus the courts and opposing
15 attorneys time because someone deliberately removed his name from the court service list?
16 Remingtons time is generally worth a minimum of $100 per hour, at least $20,000 per month, and
17 a maximum of up to several thousand dollars per hour, in high-level burl industry negotiations.
18 There have been about a dozen KNOWN incidents of document tampering, unreasonable
19 delays for top clipping issues where various documents were HELD in the file room until two
20 days before a crucial hearing for example, around 2011-13 that happened a lot, and then returned to
21 Remington one day before a hearing for corrections, when the Court assumed that no opposition or
22 initial motion had even been filed, etc. Those incidents are HIGHLY troublesome, traumatic and
23 PREJUDICIAL to any litigant especially a contientious pro per. Said top clipping merely involve
24 the approximately 4-inch long aluminum two-fingered light flat clips which are manufactured to
25 fit through the tops of documents to secure them together neatly and tightly after they have been
26 two-hole round punched for the clips to go through, and then secure the documents, with a second
27 cross piece also with holes in it at each end. All parameters such as the distance between the holes
28 and the relevant CRC sections which prescribe the requirements here, have all been fully-addressed

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1 in filed writings to the file room supervisor and all other interested participants here, including
2 Gans and the court.
3 In summary, this issue has been taken-up exhaustively and repeatedly in several, major
4 written complaints since 2009 with at least four (4) major court executives, at least three of which
5 are GONE now. The issue has also been directly addressed and discussed in open Court in
6 Department 8 on at least 4 occasions, most recently in May 2016, below.
7 13. Count #3 of 1503 FILE ROOM Obstruction of Justice. Actually going-on for MANY
8 years, since at least 2011, around May 1, 2016 a crucial SEVERANCE hearing was also cancelled
9 without notice or authority by someone at the courthouse. There have been approximately ten
10 (10) major objectionable and/or obviously felony, obstruction of justice and evidence tampering
11 incidents over recent years which very deleteriously and very prejudicially affected Remingtons
12 document filings and case presentation. In the interests of brevity and what is to Remington
13 reasonable moderation, Remington herein only describes three of those 10 serious incidents. Any
14 one of which could have instantly ended Remingtons offense or defense in one of these cases, but
15 due to a lot of alertness, anxiety and some court understanding and patience, Remington somehow
16 managed to mostly, but not completely, overcome the extreme prejudice which the file room
17 saboteur has generated over the years, especially in terms of Remingtons time, increased heart rate
18 and anxiety levels.
19 Remingtons attorney Harvey Roberts was holding on the phone and Remington was in the
20 courtroom, but the issue and crucial hearing had been mysteriously, improperly and prejudicially
21 taken-off calendar by someone with high authority at the courthouse, so it was never held.
22 Gans did not want that severance hearing to go forward at ALL, because his entire enterprises
23 strategy depended on subterfuge and keeping his frivolous case going, which BLAMED Remington
24 for all contamination on both sites, despite the scientific and logic absurdities and physical
25 IMPOSSIBILITIES of that mischaracterization possibly being true. Gans RICO trial strategy for
26 years involved prejudicing a jury against Remington as an offset to defendants contamination, and
27 he was very effective at generating superfluous and nonscientific biases. Gans desperately wanted
28 that hearing canceled, somehow managed to get that accomplished by one of his Confederates,
and eventually had to arrange the quasi- settlement complained of elsewhere herein, when it
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1 seemed likely that the cases would be severed, leaving him with a two-week possible jury trial
2 which had no damages to claim.
3 DID GANS ARRANGE SOMEHOW TO CANCEL THAT HEARING? Remington
4 thinks that is the most likely possibility, but who knows for sure? What other alternative is there?
5 No one has ever yet proved any significant intentional criminal acts around there, and Remington
6 presumes it will take a district attorney investigation to possibly get to the bottom of these multiple
7 but difficult to prove courthouse felonies perpetrated against Remington. Hopefully there are
8 similar incidents against or involving other litigants, but finding them will be difficult with nobody
9 especially motivated to do so, probably. Brissos near absolute control over the District Attorneys
10 Office and most of the courthouse is a difficult obstacle to hurdle or oppose.
11 Coincidentally,as described above, Gans was also frantically negotiating with Remingtons
12 side to settle-out his frivolous visual nuisance case against Remington. The delay in the
13 SEVERANCE hearing which Remington had briefed WELL and convincingly, played right into
14 Gans hands (why is that not surprising?) so he had time to extract another $10,000 from Farmers
15 from where he was the day the Severance hearing had been scheduled! Around the Eureka
16 courthouse, CRIME PAYS, BIG! Proving that will not be easy, but we have the time and
17 determination to at least attempt that.
18 A federal predicate act, likely NOT? But, we only need two and have over 17 major types of
19 different predicate acts, with multiple incidents of most types against many of the defendants and
20 after discovery there should be scores of additional individual, discrete incidents of mail and wire
21 fraud, including telephone frauds, alone.
22 There also have been more than 100 specific incidents of felony vandalism and property
23 destruction, which may mostly not be federal predicate acts, however in conjunction with the
24 overall dominating theme of extortion allegations, which has been Gans Enterprises basic
25 purpose and primary weapon against Remington for years, collectively they are very
26 powerful, very incriminating and hopefully will lead to some prison time for the TOP several
27 perpetrators, at a minimum. Therefore, Remingtons 25-40 legitimate, diverse, serious and long-
28 time continuity federal predicate acts in violation of 1961, should suffice, federally, whereas the
other continuous state corruption, dirty tricks, lies and deceptions are also a routine part of the
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1 racketeering enterprises daily activities, as discussed, and many of those will be quickly upgraded
2 to federal crimes when Gans must now begin his massive deceptions and falsifications during
3 federal discovery.
4 14. Gans created his perfect fictional Twilight Zone witness, Peter Esko, obstructing justice
5 by INVENTING and writing a script for a bogus, phantom non-existent witness27. To plaintiff
6 here, that appears to be tampering with a witness, at a minimum, if not worse. What Esko did
7 exactly has been explained several places, but very simply put: He took Blue Rocks fraudulent
8 report and then wrote a letter to all concerned in these cases that based on that report Mathsons
9 property was not contaminated and therefore he did not have to clean it up. Further, the inferences
10 from that are that if Mathson did not have to clean up his property then Remingtons property was
11 also benign and it did not have to be cleaned-up either, in Eskos opinion, writing for Melissa
12 Martel. As also explained above, Esko and the RICO enterprises false logic failed in those
13 conclusions on at least four major false premise and false conclusion logic grounds which we do
14 not need to reiterate here.
15 This on-going saga, obviously violates 18 USC 1503 and 1512, plus 1341, at least 10 times
16 over. Rather complicated, Remingtons 2015 interviews with five different will-place witnesses
17 within the Humboldt County Health Department either flatly stated or strongly inferred that Esko
18 will never testify about anything here, which is almost as though Esko might not even exist at all, but
19 if he does, he clearly is not prepared to swear under penalty of perjury about anything that he did in
20 these cases. In any case, Esko does not work there as a regular employee, probably does not live in
21 this area and may be out of state or the country, all of which we will inquire about imminently.
22 In about fall 2013, the STRONG and extremely important LAFCo connection between
23 Brisso and Martel, Director of Eurekas Department of Environmental Health created the surprise
24 Peter Esko enigma to inexplicably exonerate the Mathsons massive residential hazardous wastes
25 dump. Also, coincidently justified and pardoned in Gans brilliant illicit plan was the blessing of
26 defendants contamination of Remingtons land, all Mathsons extortive related vandalisms,
27 27
Plaintiff has been informed from well-placed sources within the Health Department that Esko will not be
testifying in any of these trials on behalf of Gans RICO enterprise and that his frivolous report based
28 solely on one-sided fraudulent test results was essentially a bluff, which has now failed and would not be
admissible as he is there to support and then defended it. Remington believes that it is understandable and
that no one else could or would attempt to defend its legitimacy, competency or integrity.
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1 evidence spoliation, racketeering, extortion, etc. Esko resolved everything, supposedly, based on the
2 one-sided, now fully refuted and proven to be an intentional, totally incompetent Gans ghost-
3 written fraudulent 123-page Blue Rock Report, too long, repetitive and archaic for anyone to
4 read and refute, except for John Aveggio. Aveggio decided to wade-through that report on his own
5 volition before his second deposition on July 1, 2011, and instantly that became among the top five
6 events in all these cases over the last 10 years, proving what Remington has alleged herein in said
7 second deposition pages 86-93, and elsewhere in that deposition.
8 The evidence proves that Esko was a corrupted member of this enterprise and never was a
9 credible scientific expert or any kind of environmental expert at all, in fact. Remingtons witness
10 indicate he is believed to have been bribed, paid a lot of money by the county to do very little or
11 otherwise improperly influenced and corrupted. Whatever the exact facts are discovered to be, he
12 made a one-sided study, wrote a biased incompetent letter based on that improper unscientific,
13 fabricated study, and he himself has been now discredited and proven to be a BIASED, one-side
14 only, proselytizing, irregular, contrived witness fictionally created by Brisso and Gans in collusion
15 with Dixon, Lancaster and Melissa Martel to fill a gaping-hole in Gans defense.
16 Creating a major, star witness to fill a needed role, and fabricating his entire report, which was
17 based solely on Gans bribed experts Ferriman and Gwinn in the first place, whom Gans had
18 already written THEIR expert reports for them, would be almost a joke in an ordinary legitimate
19 litigation, except this was SERIOUS!
20 Three (3) different local sitting and temporary state judges, none of which had any scientific
21 background or significant knowledge about these cases, took Eskos creation, expertise and
22 bureaucratic integrity as a given and were prepared to allow Gans to use him to con and deceive
23 the jury as to his veracity and credibility. In other words, Gans and Brissos RICO enterprise here
24 intentionally succeeded in deceiving three different judges on one of the very most material issues
25 in these cases. HERE, however, Remington will attack his report, reduce its significance and
26 relevance here to absurdity and depose him, IF he is even still in this country, as he retired years
27 ago from working for the County, and is now just some sort of a roving special emissary,
28 inferentially doing Martel, Brisso, Gans, and the enterprise a REALLY BIG FAVOR. Remington

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1 will be well-prepared to cross-examine the basis of that favor, and all related circumstances alluded
2 to above, if Esko even shows-up at all, which as stated above, is very gravely in doubt.
3 15. Wire fraud, 18 USC 1343. On July 16, 2015, a flagrant, false, deceptive interstate fraudulent
4 email and simultaneous US mail (with same illicit content), was actually sent to Remington while
5 he was out-of-state in Corvallis, Oregon by Ryan Plot, Gans apprenticed, nave young,
6 inexperienced attorney. That fraudulent email had everything: it contained knowingly false
7 information which Remington reasonably DID rely on, it was deceptive and erroneous (as to
8 content, subject matter and reproduction errors) and even had grievously mis-collated and missing
9 pages, which had Remington agitated, fearful and confused for about a week before belated
10 explanations were also mailed. While only one incident among 75-100 similar ones, this email was
11 a direct violation of fraud in interstate commerce.
12 16. Additional 18 USC 1343 interstate wire fraud. The August 4, 2015 email from Plotz to
13 Remington regarding his deceptive attempt to deceive Remington and obstruct justice while
14 Remington was still busy in Oregon. Said emails are now housed in Remingtons relevant file
15 awaiting the next stages of detailed evidentiary proofs and additional proceedings, and are not
16 detailed or quoted here. Defendants fraudulent, incomplete, non-responsive and frivolous
17 Declarations and all their 2015 Remingtons summary judgment (SJ) responses, were intended to
18 deceive the court, DID so, and greatly damaged Remington and the Burl Tree in the process by
19 multiplying the LOSS of his greatest resource, his wasted time, by 10-fold.
20 17. Additionally located mail fraud through-out August (e.g. the 4th, 12th and 25th) and
21 September, 2015 by Plotz and Gans, relating to their frivolous erroneous complaint amendment
22 oppositions, Remingtons 2015 SJ Oppositions, defendants SJ motions and Replies to Remingtons
23 Oppositions, and their generally abusive Discovery tactics: their continuous frivolous extortion of
24 threatening severe monetary sanctions in their every motion (NONE granted) and their attempting
25 to improperly, fraudulently and extortionately force the case terminating sanction of deposing
26 Remingtons de-designated expert Foget, whom if successfully deposed AS Remingtons expert
27 would have prevented Remingtons NEW expert Dr. McEdwards from testifying as his needed
28 expert. Those types of dirty, overzealous, unethical litigation tricks were attempted at least
monthly, however never relied upon by Remington, but ALL directly took his precious time and
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1 prevented Remington from working on profit producing burl sales and products. Cumulatively,
2 discovery and the next level of DETAIL regarding content, dates, parties and direct damages to
3 Remingtons major burl products business in EACH case, with each fraudulent scheme which
4 needed timely and time-consuming responses, will prove that MANY (more than two) examples of
5 federal wire and mail fraud exist here, where Remington does not depend on ANY to prove a
6 federal predicate felonious pattern, rather a clear racketeering scheme as described involving
7 MANY unethical and illegal acts plus a few serious federal predicate acts mostly relied upon by
8 Remington and his attorney, Harvey Roberts.
9 18. More 18 USC 1951 and 1503 violations. From 2008 to January 2017 (and continuing),
10 John Mathsons extortive felony fence destruction, equipment, window and garden VANDALISMS
11 kept the enterprises pressure-on Remington daily, especially around state case filing deadlines. By
12 2013, every time a major multiple hundred page document final was imminent or due for final
13 drafting and word-processing, during the last few days Gans would always notify his soldier and
14 ventriloquists DUMMY Mathson (and his substance abusers) and tell him to breakdown
15 Remingtons fences again and flood Remingtons land with deer and vagrants. Therefore, as
16 Remington came in his front gate he could often expect to see 3-4 big deer (that can eat 8 pounds of
17 rose flowers and tender young shoots in a day) meandering calmly and ostentatiously amongst his
18 weakest roses, as if they owned the place. Looking for the Mathson-cut holes and then arranging for
19 a dog to chaise them away usually took 24 hours in most cases, in most years, and distracted
20 Remington considerably in the meantime.
21 Probably only a sensitive and sympathetic older jury could evaluate the significance of
22 those hostile, sadistic intentional acts and place a dollar value on that to the Burl Tree, and measure
23 the emotional toll on an old guy in his mid-70s. Remington keeps business records of most
24 significant acts and events here and when required can provide endless details on top of THESE
25 documents documenting the time, place, damages and photographs of same in many cases as
26 Remington is a SERIOUS photographer with professional skill, equipment and graphics
27 capabilities. Again, as above, today (11-16-16) the new gate damages in two places were
28 photographed about 9 times, including before and AFTER repairs. As documented above, by mid-
March 2017, there had been another 10 or more major attacks in the main front gate area. Assuming
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1 only one deer entered after dark, and then left by afternoon, probably in THIS season, damages of
2 about $3-500 of delicate roses and Japanese maples, rare Fuchsias, etc, were eaten and ruined today.
3 It was not known on 11-16-16 whether the deer was still HERE or not, or whether five others aware
4 also here, and only tracks and a few more days and ruined plants will accurately determine that.
5 19. 18 USC 1951 (extortion) and 18 USC 1512 (witness tampering) by RAO on Marsh.
6 On November 14, 2015, and for several days of prior planning, Wayne Marsh, replaced
7 the scared-off Figas, at Figas request, becoming Remingtons new excavator operator and
8 remediation contractor expert witness. However, RAO heard about that from Figas, in an as yet
9 undetermined manner, and Marsh was then similarly bribed, threatened, coerced, intimidated,
10 extorted or even possibly blackmailed into NOT showing-up for work, to do the job he had just
11 promised the night before. We went over all details (again) Friday evening, but 12 hours later RAO
12 reached marsh and prevented him from working here, just as they had with Figas. That Saturday the
13 rains came-in and washed-out the job for another year.
14 20. 18 USC 1503, and 1512 Obstruction of Justice, and altering, destroying, mutilating
15 and concealing evidence to prevent its use at an official proceeding, here several TRIALS, in
16 and prior to 2015. Specifically, as per surveillance video proofs, in December 2015 and into
17 March 2016, in a major felonious manner, John Mathson continued Gans major stealthy vandalism
18 and evidence spoliation and REMOVAL program, wherein the CONTAMINATED HAZARDOUS
19 DUMP SITE on Remingtons land now looks superficially remediated. Detailed surveillance video
20 footage exists, from multiple cameras and angles of John Mathsons trespasses through his secret
21 doors, gathering and dispersing redwood needles and rolling, lifting and disposing of asbestos pipes
22 into his double-gated secure storage areas, during this period.
23 Like broom-sweeping a nuclear radioactive spill, what John Mathson has done and continues
24 to do here is to conceal and disguise deeply buried hazardous debris and pretend the invisible
25 vapors, dusts and microscopic airborne Chrysotile fibers dont exist. Gans smart RICO purpose
26 became clear in May 2015:
27 To a jury and ordinary people if it looks messy it probably is contaminated, and if it
28 looks clean, well-kept and BROOM SWEPT then inferentially it IS PRISTINE and
uncontaminated! Hell with the scientific tests, what do they show and what do the nerdy
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1 guys with thick glasses know, anyway? Remington had requested a jury visit around January-
2 March 2016 to view first hand what the 2008-11 photos showed: massive contaminated and
3 adverse debris all over the lands surface, which extended 10-15 deep on average. Removing the
4 surface debris and covering the emerging 15,000# concrete blocks with redwood needles and
5 orange wild lilies gave the sites the artificial appearance of an almost normal redwood forest again,
6 if you did not look too closely.
7 Gans well-executed RICO corrupt plan was to corrupt the site and to visually deceive the
8 jury. Now, after Gans removed all of the incriminating visual surface evidence, When the jury
9 visited they would see nothing, and what looked like a benign and uncontaminated site. As
10 explained, that was because John Mathson and his men, under Gans personal approving
11 supervision, as proven by surveillance video, had REMOVED by hand and covered virtually all
12 visible contaminants, covered he huge immovable and unbreakable objects with organic materials
13 or broken-them-up smaller, such that most contamination was concealed in dirt-and brush covered
14 piles 15 deep, but looked clean on the surface.
15 Gans theory was: Whats a jury going to believe: its own EYES or some lying over-paid
16 experts, a lot of tests which proved numerous invisible contaminants, and a bunch of old obsolete
17 2008 photographs that may have been altered, and which in any event had been taken by the
18 biased sell at Remington, at least according to Gans?
19 Altering a crime scene is a felony in most states and in most cases, although California
20 Supreme Court state law has become ambiguous and favors sanctions over prison sentences.
21 However, if OJ had removed the bodies, wiped-up blood on gates and driveways and then hosed-
22 down the concrete for 2-3 hours BEFORE the police got there, that would appear to be a CRIME.
23 Here, Mathson did just that but for years, and especially for 3 months in winter 2016, when several
24 experts (from BOTH sides) were invited and imminent, many new current photos were being taken
25 and a jury and judge were about 60% likely to be arriving for a detailed close-up site inspection. At
26 the moment, During 2016 Judge Reinholtsen has stymied that request, but that could change, and
27 probably will with subsequent unbiased courts from both the state and federal systems.
28 To Remington, and the only attorneys he has discussed this with, what John Mathson did is
felonious evidence tampering to eliminate most of the visual evidence against him in a visually
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1 based case! As a result, Remington is requesting terminal evidentiary sanctions against Gans and
2 Mathson and a declaration that liability is established and the 2008 photos and depth tests are now
3 proven, established and stipulated. In other words, defendants have to REMOVE everything they
4 placed here. If they want to swear that they cleaned-it-all up and little remains that is fine, but
5 ONLY if they agree to now start DIGGING and keep removing the remaining millions of pounds of
6 hazardous wastes until NOTHING remains except pristine redwood forest loams.
7 21. 18 USC 1503, & 1512-13 Obstruction of Justice, in this case; altering, destroying,
8 mutilating and concealing evidence to impair its integrity, REMOVE it entirely and/or
9 prevent its use, in any case at the several scheduled and future trials herein, this count
10 referring specifically to January until May 5, 2016, and Remingtons evidence for that period.
11 The above-described evidence tampering continued seriously, and differently in some
12 respects, into February-April, 2016 and Remingtons experts depositions and site visits, greatly
13 confusing and minimized the visual impact of site visits and reduced the value of the evidence
14 photos from 2008, to near absurdity, in that they now require an explanationAnd substantial
15 evidence from Remington, and ONLY he can do that. John Aveggios unexpected premature death
16 and Fogets subsequent RICO removal have left Remington with no one else who can fully and
17 emphatically VOUCH for what was and IS still there, buried deep under dirt and concealing debris.
18 Mathsons tampering and removal of evidence (from this murder site of the land) was well-
19 captured on surveillance video prior to March 2016, however after that John Mathson has been
20 much more careful and circumspect, after Remington complained every other day during pretrial
21 hearings about Mathson, et als vandalisms and spoliation in 3-hour pretrial hearings lasting for
22 more than 100 days. During that time he needed to explain his surveillance systems to the Court
23 with Gans and John Mathson sitting right THERE at the table only 15 away, daily. Eventually,
24 Gans and Mathson appear to have gotten some of the message, and thereafter became more
25 circumspect and careful in their vandalisms and incursions and in particular they attacked new areas
26 far from Mathsons property and gates where most of the cameras were originally focused On to.
27 Thereafter, the best Defendants criminal-acting in Remingtons outdoor property surveillance
28 videos ceased completely, but then gradually started up again a few months later, because John
Mathson just loves what he does too much to fully go straight. He is obviously a true criminal,
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1 fully-possessed by out-of-control hate and a need for the adrenaline rushes of criminality and
2 attempting to evade detection by infrared motion video cameras.
3 22. Gans IMPORTANT February 10, 2016 intimidating, extortive phone call, 1951, Hobbs
4 Act violation.
5 Remington called Gans around 4 PM to request that the depositions of Dr. McEdwards and
6 Ms. Hoyos be set for 4 hours later in the day to accommodate our schedules and conveniences, and
7 Gans refused in a reasonably pleasant, rather plaintiff and pitiful manner at first, because he
8 saw this as a fantastic once in 3-4 year opportunity to astutely and psychologically evaluate
9 Remingtons present plans, trial preparations, anxiety, confidence, motivational and resolve levels,
10 only a few weeks before the first scheduled trial. In other words, in the artful hands of a RICO
11 family chieftain, this was an invaluable opportunity which Gans immediately recognized and then
12 took full advantage of.
13 A few minutes into the conversation, Gans went through an almost rehearsed couple minute
14 speech on how nice it would be to end these cases, which to him entailed Remington dropping his
15 abusive charges against the poor, nice Mathsons, who just want their life to go back the way it
16 was, etc., presumably to see if Remington felt the same way and was losing his resolve to continue
17 these cases to the bitter end, the death of all parties, or both. However, early on in the conversation,
18 Remington made it very clear and honest that he was not BUYING ANY of that after Gans
19 specifically rudely, callously and flatly refused to consider Remingtons reasonably-based
20 deposition hour rescheduling requests, to accommodate Remingtons serious, miscellaneous related
21 health issues, at that time.
22 Next, being the smart negotiator and good deceitful actor and LIAR that he is, Gans
23 conspicuously reversed course and tried a HARDER line (to see if that might stick), but only
24 after seeing that his nice-guy, beaten-down, poor, tortured, pitiful & sympathetic Mathsons
25 approach was failing miserably, and in fact was getting an angry response from Remington, which
26 was the exact opposite reaction he had hoped for.
27 Therefore, next, Gans tried his get real & threatening approach. He angrily,
28 improperly, (quite irritatingly to Remington), unprofessionally (and criminally, California and
federal extortion case law now confirms), threatened Remington with total defeat, and declared:
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1 Well destroy you, if you keep this up....(and continue on the present litigatory path), adding
2 a little bit more about their obviously overwhelming financial advantages, immense motivations
3 and the unfortunate fact that they are all getting paid to do this while Remington goes into financial
4 ruin; which when summarized means that they can continue all this with great enjoyment, until
5 Remington was either overwhelmed or gone. In other words, supposedly the Mathsons were
6 miserable and wanted to end this, but obviously the others (who Remington today would
7 characterize as the other 35 RICO enterprise members felt the opposite) wanted this to go on
8 indefinitely, and clearly they would and will.
9 Initially, Remington was primarily shaken and angered by Gans refusal to bend at all or to
10 respond to the sole purpose of Remingtons call, which was to reschedule two deposition times
11 about 4-6 hours later. Gans and Remington both knew that he had set two crucial depositions,
12 which had to be taken quickly, about 5 hours before Remington normally even gets-up and even
13 starts breakfast, which deposition scheduling times have been a major dispute for at least eight
14 years but in the past and always been 100% resolved and compromised.
15 Attempting to make THAT compromise once again was the only purpose of Remingtons call,
16 however, as explained, Gans took that very rare personal communication opportunity to first
17 negotiate, then plead for the poor Mathsons and finally to SEND Remington a message, which
18 was a RICO predicate act.
19 Candidly, Remington was also a bit fearful of Gans abrupt ANGER, although not really
20 relying on his threats then, although basically just being angered and somewhat awed and
21 intimidated by them. A year later, Remington now understands exactly where Gans was coming
22 from and that he does have an ominous, powerful, motivated enterprise of more than 40 members,
23 not all named yet in this RICO action, and they have the overwhelming CONFIDENCE that
24 unlimited financial power, including their regular gigantic paychecks and all-expenses-paid, brings.
25 Also, in that conversation, Gans next improperly demanded that Remington pay the
26 $12,000 debt owed to the enterprise; and thus, after the nice guy approach apparently failed,
27 Gans actually audaciously attempted the racketeering enforcer approach and Mafia -like shake-
28 down threats of: Pay us the money you owe us now, OR ELSE.... Similar demands have been

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1 made in writing, BY THEM, about once a year. And here in early 2016 they itemized their
2 monetary demands in a letter about a month later, just to clearly reiterate their RICO objective of
3 first winning these cases, and then destroying Remington and the Burl Tree financially. As is been
4 made clear throughout these documents, their employment of extortion, intimidation and fear is the
5 cornerstone of their frivolous defense, which actually has zero other scientific basis. In other words,
6 if they cant scare Remington away, they will eventually have to pay to clean up his property.
7 Remingtons initial contemporaneous RESPONSE on 2-10-16 to that new extortion was: I
8 have been paying, (your protection racketeering money) especially a few years ago, but stopped
9 when Remingtons bank balance was getting intentionally fouled-up by Gans NOT CASHING any
10 of the checks totaling more than $1000. Remington keeps his money INVESTED in appreciating
11 assets and therefore does NOT automatically maintain several thousand dollars in that Bank of
12 America checking account Gans had by that time taken effective control over. In other words,
13 the fear that we, in my bookkeeper wife especially, had was that Gans would hold a couple
14 thousand dollars of uncashed checks and then put them all in unexpectedly to cause a banking
15 crises that Gans could use to prejudice Remington within the courts, in an attempt to make the pro
16 per Remington look bad or even worse than he already did, to the courts, etc.
17 Therefore, one of our next discussions, in what was a pretty long phone conversation, related
18 to: Why had the RICO enterprise not even cashed the checks Remington HAD sent them to date?
19 Gans has never answered that question which has been asked several different times. Rather clearly,
20 Gans likes to hold that fear, and substantial monetary amount as leverage over Remington,
21 and additionally and importantly it has always been conceded during settlements that forgiving all
22 Remington debt would be included in any future global settlement regarding remediation of the
23 sites plus resolution of all other obligations and problems between the parties. Therefore, we can
24 only conclude that on this date Gans threatened Remington was some sort of immediate collection
25 actions of the entire amount all at one time, in order to make them fearful and to extort an
26 immediate settlement in terms of the RICO enterprises objectives.
27 We discussed all that, without using the word RICO, and thereafter Gans shut-up about the
28 debt at that point without specifically escalating his threat to the degree of offering me protection
from Mathsons gang if Remington paid up immediately, nor did he threaten to put out a contract
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1 on (Remington) for non-payment of a mob, or racketeering enterprise, debt, at that time in early
2 2016. As discussed below, and also above, by June 2016, the enterprise was much more angry, less
3 circumspect and much more direct in their specific extorting link between Remington agreeing to
4 end all of this, in exchange for defendants ending all of their continuous destructive acts of
5 increasing number and violence during 2016. in effect, this phone call was Gans first link between
6 trading peace at the properties between the litigants, in exchange for Remington dropping all of
7 his lawsuits and disappearing from the street, and from Mathsons life essentially.
8 Finally, in that same conversation, and in the context of the $13,000 or so amount which
9 Remington owed the enterprise, Gans climaxing threat was: When we win these cases in the
10 very near future we are then going to sue you for several hundred thousand dollars of costs
11 and attorney fees, so if you think the $13,000 now is bad, you will very soon be RUINED
12 FINANCIALLY completely if you dont drop these cases now!
13 As explained throughout these documents, Gans RICO threats and extortion against
14 Remington specifically, began very seriously in early 2016. Here, he intimidated and seriously
15 threatened Remington with imminent financial ruin with the DIRECT BELIEVABLE
16 THREAT and specter of Allieds suing Remington for ALL their costs and attorneys fees for
17 ten (10+) years, plus punitive and/or additional damages for malicious prosecutions, and
18 intentionally inflicting emotional damages on the poor Mathsons, ETC.
19 Four months later, Gans made these protection racketeering threats much more plain, directly
20 and illegally, when he expressed it as a quid pro quo, during the June, 2016 courthouse corridor
21 haranguing, saying in effect: THEY are very angry and are going to ruin you financially.
22 Therefore what you need to do is drop all of these lawsuits and we will drop all of our legal
23 and extralegal destructive activities which you have been complaining about and suffering
24 from.
25 23. 18 USC 1341, Mail fraud, March 3, 2016. Three (3) additional examples of the
26 numerous defendants MAIL FRAUDS, follow here which related to Remingtons Severance
27 Motion. Many of those US mail frauds were supplemented and magnified as emailed wire frauds,
28 as will be researched and presented at trial.

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1 This group of 10-20 multiple mail and wire frauds occurred throughout March 2016, and even
2 into April, and also had some accompanying emails and phone calls, and some of them also
3 involved Remingtons attorney Harvey Roberts, by telephone email and US mail. The scheduled
4 April 1, 2016 severance hearing was the anticipated climax of this severance correspondence
5 sequence, but when defendants concluded that they were losing this severance debate, they quickly
6 preempted it by soliciting a settlement with Farmers insurance which would successfully end their
7 case and result in a $20,000 extortion profit for the Mathsons, as explained at #34 BELOW.
8 The first mail fraud in the sequence was a letter from Gans dated March 3, 2016 which ordered,
9 intimidated and in effect extorted Remington to withdraw his basic good faith severance motion or
10 face severe sanctions or worse. It was a lengthy and substantive letter, which defendants have in
11 their possession and much of the substantive contents are briefly outlined at #24 below dated March
12 17, 2016. In essence this letter was a threat for sanctions under CCP 128.7 (h), which threats were
13 brought in bad faith for an improper and frivolous purpose.
14 24. 18 USC 1341, Mail fraud, March 17, 2016. This intentional fraud by Ryan Plotz occurred
15 in his Opposition to plaintiffs motion to sever DR 080669 and DR 080678; request for sanctions
16 pursuant to CCP 128.5. Although too long to adequately paraphrase here, Plotz started out by
17 deliberately falsely equating the factual situations in the cases on March 3, 2016 with those that
18 existed seven long years earlier on March 9, 2009. In essence, he fraudulently misrepresented to
19 the court and Remington that nothing had changed in the cases and 7-8 years, and then deceitfully
20 quoted Remingtons own words from seven years before to logically prove that false point, and
21 LIE! That was outrageous, and was just another one of the 20-30 knowingly false statements which
22 Plotz wrote in these and other opposition documents all in express and specific violation of CCP
23 128.7 and 128.5, as we have complained about elsewhere.
24 That is substantially because the cases significant facts and parameters as outlined by Plotz
25 had all changed more than 90% during those seven years. When things like FACTS change 90%
26 they are not identical, and although apparently only unethical mischaracterizations, tricks, false
27 logic and/or fraudulent misrepresentations here in state court, when Plotz, Gans, Brisso and some of
28 these others are asked these questions under oath in the federal case, we are going to have real
provable perjury and fraud, which will be harder to get away with in San Francisco than in Eureka.
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1 The numerous, dozen or more specific material frauds written by Plotz in that mail
2 fraud Opposition included, without limitation:
3 By 2016, severance was justified because there were virtually no shared facts remaining
4 between those two cases; the convenience of both parties were not improved by consolidation, but
5 actually the reverse is true; Plotz claims that the majority of counsel would be served by leaving the
6 cases consolidated, which was an especially egregious fraud, specifically involving Remingtons
7 homeowners insurance attorney Harvey Roberts. Were he required to sit through all of
8 Remingtons contamination trials and pretrial hearings which actually took four, continuous solid
9 months without ever reaching a conclusion, that would have cost Farmers Insurance an estimated at
10 least another $100,000 if not $200,000; as Plotz well knew, obviously there was no danger of
11 inconsistent rulings when only one judge was presiding over both cases for all purposes; Further,
12 the fence issue had long since been resolved completely before 2016, and was an entirely obsolete
13 issue in DR080678 by 2016;
14 Whereas, because the fence issue was defendants main Jury prejudicial issue to improperly
15 use against Remington, in their obsolete and frivolous DR080669, which they intended to use it for
16 great prejudicial value, with several witnesses with the jury, it was of extreme importance to them
17 but equally as important to Remington to keep out of the trial. Nevertheless, defendants still
18 managed to illicitly use the obsolete fence issue to conclusively prejudice the jury in the 2016
19 SOL trial of DR 0806768; The facts are that Severance at least HALVES the trial time for the
20 reasons which Remington expressed in detail in his Declaration and Reply Memorandums and did
21 not double it as Plotz fraudulently alleged; Contrary to what Plotz knowingly mischaracterized, the
22 boundary line between the properties is not an issue in either case and had been resolved and
23 stipulated to many years ago; Contrary to Plotzs bad faith Opposition, there was no substantial
24 development by Remington on-Mathsons land inside the fence at any time and certainly nothing
25 exists there today; Nor was Remingtons water circulation system ever a significant factor in
26 either case , and in any event was certainly no reason for keeping two disparate cases consolidated;
27 Also, the fence is now entirely irrelevant in DR080678 as was the fill south of it throughout
28 these cases because it was only discovered 2-3 years after said fence was constructed beginning
around 2003; Additionally, Plotz made reference to their fraudulent and unsubstantiated spiking
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1 allegations by Remington, which refers to their false claim that Remington contaminated his own
2 property; Finally, there remain very few common facts between the two cases and certainly no
3 common jury instructions of any consequence. Overall, there can be no doubt that this plots
4 opposition was entirely false and knowingly fraudulent in violation of federal mail fraud statutes.
5 25. 18 USC 1341, Mail Fraud, March 17, 2016. Mr. Plotzs false declaration of that same
6 March 2016 day was totally riddled with mischaracterizations, false facts and was specifically
7 intended to mislead and defraud the court, but mostly to intimidate, coerce and extort Remington,
8 as entirely consistent with all the contents herein, and as now explained:
9 On or about March 3, 2016 Remington filed his severance motion to un-consolidate the two
10 cases referenced above, because there was no longer any reasonable basis for keeping them tethered
11 at a trial. Remingtons motion was in good faith and based entirely on the facts, but that same day
12 the letter referenced above from Gans threatened Remington with drastic consequences including
13 major sanctions under CCP 128.5 and 128.7. Some of Gans frivolous and fraudulent arguments
14 were paraphrased above, but simply put Remington declined to withdraw his motion and it
15 proceeded as scheduled, although before it was ever heard by a judge Gans capitulated, and took
16 the $20,000 extortive (Racketeering protection) fee from Farmers and called it good. As explained
17 below, eventually Gans solicited Farmers for $20,000, after declining to accept only $10,000, in
18 exchange for protection from his frivolous litigation, DR 080669. Farmers gladly paid the $20,000
19 because defending Remington in that lawsuit, especially if consolidation was still in effect, could
20 have cost them much more than $100,000, potentially $3-400,000, or very possibly even more, or
21 MUCH more if Gans RICO enterprise presented a false and fraudulent case for punitive or
22 emotional damages, which a jury was deceived and tricked into accepting.
23 In any case, Remington regards this entire intense episode in March 2016 as just another
24 major extortion attempt by Gans, only in this case it was successful. Gans extorted Farmers for
25 $20,000. He easily got $20,000 for his nice, abused and beaten-down clients the Mathsons and
26 more importantly, he also got rid of Remingtons attorney at the same time. Therefore, in this case
27 Gans extortion hurt and injured Remington arguably for $100,000-200,000 (OR potentially much
28 more if Remington loses the case as to pay costs or punitive damages etc.), got rid of his specialized
trial attorney and left Remington alone to battle Gans and his enterprise for what turned-out to be
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1 four (4) consecutive months just to get through the 2016 SOL trial. Said SOL trial actually
2 accomplished next to nothing except to prove Gans further and successful fraudulent attempt to
3 deceive the court in particular about Californias continuing nuisance and trespass law, where
4 Remington has a statutory right to elect which allegation to pursue, and then it is up to a jury
5 during a TRIAL, and not up to the inferentially biased Judge Reinholtsen to determine whether
6 remediation can be done using reasonable means at a reasonable cost, Supra, Mangini II.
7 Remington considers this episode to be additional, provable documented RICO defendants
8 mail fraud on many different levels. For example, both Plotz and Gans threatened Remington under
9 CCP 128.7, but defendants violated section (h) of that statute in so doing. First, Remington was
10 then a represented party (in DR 080669) and suing him for sanctions was therefore inappropriate
11 as the statute reads. Also, it is obvious and will be proven at a trial that these threats of sanctions
12 were frivolous and were clearly brought only for an improper purpose which was to scare,
13 intimidate, coerce and extort Remington, with the intention of forcing him to bend-over and drop
14 his severance motion, which potentially would have devastating consequences for defendants, were
15 Remington to win it as was likely.
16 With that background, specifically Remington here objects to Plotzs extortive declaration
17 where he provides great detail in falsely presenting some very inflated attorney fees purportedly
18 because Remington had not withdrawn his severance motion. Simply put, both Gans and Plotz
19 requested $3030, which is clearly substantially more than double the amount of money that they
20 were actually paid to do that work, or that which was reimbursed to them by Allied. weve been
21 down this road before, and Defendants always grossly inflate their attorney fees. In the pastWe
22 established in Judge Miles court that all of the Mitchell firm attorneys think that they can make a
23 gross profit off of Remington on their attorney fees, and charge him at least double what they
24 are actually paid, with the net effect that if successful, Allied would make a more than 100% profit
25 on what they actually did pay to the Mitchell firm attorneys.
26 Mr. Plotz makes under $100 an hour, yet sought $225 per hour as though this were some sort
27 of a Special motion-like Lodestar attorney fee situation, which it was not.
28 Further, Gans has been proven in the past to make no more than $150 per hour, and not $300
per hour, or anything remotely close. We went through all this in 2008-11 and this was not a Special
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1 Motion with Lodestar-type attorney fees recoverable and written into the statute. These frivolous
2 and extortive threats of grave sanctions against Remington were made on grossly frivolous grounds
3 and defendants also requested obviously inflated an unconscionable sums of money, purely as an
4 intimidation tactic.
5 26. 18 USC 1341, Mail Fraud, March 17, 2016, This time by Gans in his so-called
6 Supplemental Opposition and Objections to Joinder in Remingtons motion to sever and further
7 Memorandum of Points and Authorities. Again, Remington alleges that this document was also
8 solely intended to intimidate and extort Remington into dropping his lawsuits and giving he
9 Mathsons his land essentially free.
10 The background of this entire improper memorandum has been provided above. Essentially
11 Gans unethical and dishonest advocacy practices from about 2008 to 2012 eventually led to pure
12 criminality by 2016. Remingtons documents from several years ago are filled with complaints
13 however he was just a little bit too stupid and naive to realize that he was actually being assaulted
14 by a RICO criminal enterprise since about 2012.
15 Beginning in early 2016 and it became clear that Gans primary two trial themes were going to
16 be that: (1) Remington contaminated his own property and that contamination went down the
17 mountain under the Creek and up onto the mountainside where the dumps were located. In essence
18 Remington caused all the contamination on both properties and apparently Gans argument is going
19 to be that he moved more than 2 million pounds of asbestos pipes and other contaminated debris
20 through impassable obstacles in mountain terrain by hand wheelbarrow, because no equipment
21 could get anywhere near there from Remingtons land; (2) Gans other major theme which she
22 believed he could trick a jury and trial judge about was that Remingtons untidy yard and alleged
23 visual nuisance was equal to contamination. Which is just another way of saying the same thing
24 that because Remingtons equipment and Burl storage is somewhat sloppy and disorganized, that
25 means his property is contaminated. And again, Gans fraudulent interpretation of contamination,
26 which he might have been able to trick a jury with, is that hydrocarbon and contaminated waste
27 contamination is analogous to radioactive waste, which can be transmitted through the air. Although
28 some of the defendants contaminants can and have become airborne, what Remington has on his

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1 property was not contaminated in the first place, but in any event could not have contaminated the
2 soils and waters hundred yards away on a different mountainside.
3 As an additional adjunct of Gans two knowingly false and fraudulent arguments above, he
4 made the additional frivolous, devious and knowingly deceptive false argument that if one broom-
5 sweeps a hazardous waste dump such that the surface of it looks clean, then it is in effect
6 remediated, safe and can therefore be ignored because the few inch veneer of soil and grass
7 permanently protects the public from all future contamination and toxicity. Gans has used that
8 argument extensively for years now and issued orders to Mathson to remove all evidence of
9 contaminants on the surface of the land as best he could to make it look like there was nothing
10 there, and if theres nothing there then there is no problem and no cleanup necessary. Again, this is
11 mere Gans fraudulent deception and concealment, wherein defendants contaminated waste dump
12 complained of herein consist of several million pounds of hazardous wastes which go 10 to 20 feet
13 deep into the ground, and what is on the surface is not that important, when you consider that the
14 waters traveling deep within the dump come out the low on Remingtons land with extreme toxicity
15 and contamination, which has caused an imminent threat to the creek and the wider environment.
16 Additionally, Gans memorandum again falsely repudiates Remingtons testing on his
17 property without any evidence or proof thereof; which further relates to the longtime dance trick of
18 misleading Remington into believing what Gans said that his intentions were, which he falsely said
19 were for his Blue Rock experts to conduct testing himself all over Remingtons land. When Gans
20 successfully tricked and fraudulently conned Remington into believing and reasonably relying upon
21 that, Remington then reasonably decided not to do his own timely testing on his own land, because
22 he did not believe it made logical, efficiency or monetary sense for him to spend an extra $10,000
23 to conduct tests that Gans had said and promised that he was going to repeat anyway. Therefore, to
24 an honest and forthright Remington, presumably just one set of tests would be sufficient, because
25 since all tests on Remington property have been generally consistent with each other and sense
26 Remington assumed that Gans tests would be done honestly and properly according to law,
27 therefore overall it made no sense to do many thousands of dollars of overlapping and unnecessary
28 tests, especially in view of the facts that all the experts could see and smell hydrocarbon, asbestos
and other contamination every time they visited the sites. In any case, Remington made a serious
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1 mistake in relying on Gans veracity, integrity and word in 2010-2011, and that deception by Gans
2 and Remingtons reasonable sworn explanation of it, was previously accepted by Judge Reinholtsen
3 as valid back in 2011, presumably because he knows a little bit about Gans tricky behavior. In
4 2011, Judge Reinholtsen was still very fair and neutral, and it was only during 2016 that something
5 snapped and said Judge suddenly went at least 98% in favor of Gans and ALL of the Enterprises
6 requests and elicit purposes. Remington has inferred specific bribery and improper influences as
7 thoroughly describedAbove and below, But obviously there are a few other possibilities which may
8 eventually be discovered, or perhaps not. If all of these cases and issues are heard and adjudicated
9 in federal court, then Judge Reinholtsens bias or integrity issues will never need to be fully
10 understood or proven.
11 Next, at page 4: 8-13, Gans discusses how he may have to use his unprovable accusations
12 regarding Remingtons spiked test results. Then he continues on about the RICO enterprises false
13 and unproven accusations that there are numerous sources of degraded hydrocarbons located on
14 Remingtons property, and threatens that hes going to explain how Remington spreads such
15 toxins on his land and on the Mathsons, maybe believing that they have some sort of magical
16 fertilizing effect on his massive rare gardens. Additionally, Gans says that he plans to use Mathsons
17 false observations of Mr. Remington punching holes on the subject area of fill and pouring fluid
18 into them.
19 Gans final threats, false fictional accusations and extortive attempts to make Remington give
20 up his lawsuits, are provided in his final paragraph on page 4: 14-19: Certainly, however, if
21 additional testing is admitted in direct contravention to the parties long-standing expectations and
22 this courts prior orders, then the Mathsons intend to introduce testimony that certain testing results,
23 which detected a plethora of pollutants including fresh diesel in a hand-dug hole on Mr.
24 Remingtons property, were fabricated by Mr. Remington, and responsive testing which further
25 demonstrates that point.
26 Since none of those Gans statements are true, provable, possible or have any factual or
27 material evidentiary basis, Remington considers them cumulatively to be another federal
28 predicate extortive act of mail fraud intended to fulfill the clear purposes of the RICO enterprise,
as delineated herein.
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1 27. Improper expert investigations and blatant unlawful trespasses onto Remingtons land,
2 five (5) years after the discovery cut-off, violating 1503, et seq and 18 USC 1951, which
3 cumulatively can be called the flagrant 2016 RICO Hillyard extortion attempt.
4 On March 19, 2016, beginning around 8:12 AM, 2016, two different surveillance video
5 cameras show Gans, Mathson and Schwartz or some new unidentified expert, that Remington has
6 never seen, visiting the contaminated sites, with great interest and considerable note-taking. One
7 unidentified man with an aluminum clipboard, who did not appear to be Pulley or Hillyard was
8 seen, which infers Gans was looking for a new WHORE expert to sign-off on and SWEAR in
9 court to whatever self-serving fiction that Gans writes for him, the same way that Ferriman, Pulley
10 and Gwinn have been doing. Hillyard would appear to be their man, willing, able and excited to
11 assist in the RICO enterprises criminal racketeering objectives against Remington. That is how
12 Gans deceitfully and unethically works, and with no other valid scientific defense or any scientific
13 testing at all on Remingtons land, fraudulent deceptions and tricks that confuse, deceive and
14 prejudice an unsophisticated nonscientific jury, appear to be the only way that Gans can possibly
15 defend this case, in Remingtons view.
16 Additionally, human TRACKS, noticed several days later in the soft dirt along said fence
17 indicated that they used one of Mathsons several not so secret-doors trespassing through and/or
18 across the agreed fence, violating Remingtons No Trespassing, Violators will be Prosecuted
19 signs, in addition to all civilized, California inspection, notification and permission protocols.
20 March 2016 was 5-years beyond the statutory close of discovery deadline, so no plaintiffs
21 permission to trespass on his property or order from the Superior Court could have possibly been
22 obtained to legally justify Hillyards illegal testing on Remingtons land or anywhere.
23 However, little problems like breaking into Remingtons yard and trespassing anywhere
24 defendants feel like it, do not thwart and never have even slowed-down the Enterprises shake-
25 down racket. Similarly, when Humboldt County denied Mathsons requests to build a second
26 septic system behind his house, because their land was unsuitable for percolation, which caused the
27 failure of their first system, that only slowed down their project by a few days.
28 What Remington specifically alleges here, as will be further developed in discovery and
depositions, is that March 19, 2017, as partially recorded on surveillance video, was likely the day
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1 that Hillyard made his illicit and extortive visit to Remingtons property, wherein, thereafter Gans
2 committed additional mail fraud and extortion by cleverly and fearfully intimating, without
3 providing any of the specifics to Remington, that Hillyard had done some very important,
4 significant but unknown work, at unknown locations on some unknown portion of inferentially
5 Remingtons property, or a few inches from it which would also have been inside Remington
6 security fences. A good extortion scheme deliberately leaves some of the details murky and
7 obscured so that the victims imagination can fill in the most horrible possible details. Gans
8 understands all of that brilliantly.
9 Maybe Hillyard tested on Mathsons land or maybe it was in Remingtons swamp where most
10 of our 2011 testing was conducted, but the mysterious and deliberately ominous inference was
11 that it was near to, and above the swamp and/or possibly sampled, or attempted to do so, some of
12 Mathsons Springs which feed the swamp, which get there from the east and not from the north.
13 Whatever they did, it was obviously meaningless because there is no water at all up above the
14 swamp, know useful details were provided to Remington to make any sense out of anything that
15 they claim they did, and all details of water flows across Remingtons property are entirely
16 unknown to defendants, despite their couple of brief walk-throughs of the area, and most
17 importantly, some young guy just getting off the bus from Portland for a couple of hours, would
18 never be able to understand anything about the hydrological dynamics of these sites.
19 Cleverly using pure and classic extortive tactics, Gans provided a vague and only partial
20 explanation of what was done by Hillyard and where, with the obvious intent to generate some sort
21 of vague fear in Remington, if in fact he had anything to hide, which he didnt.
22 It is well-known to experts, and JUDGES on successful extortion techniques, that the more
23 vague and general the terms of the accusation the better it would subserve the purpose of the
24 accuser in magnifying the fears of his victim, and the better also it would serve to protect him in the
25 event of failure to accomplish his extortion and (if he is prosecuted for) for his attempted crime,
26 People v. Bolanos, 49 Cal App. 2d 308 (1942).
27 Defendants essentially make their own law over on Mathsons property and also now on
28 Remingtons, have not received or even sought permits for about 90% of their development over
there, and when any of the defendants want to do something, they just do it whether its legal or not.
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1 Hence, cumulatively they are outlaws in violation of numerous county, state and federal laws.
2 The above cited unauthorized entry to and investigations of Remingtons land in violation
3 of California law, were not a federal crime arguably, but provide a further indication of Gans lack
4 of required attorney ethics and scruples and further demonstrates how he basically makes his own
5 law and does whatever suits his expediency. Like almost all of the incidents and alleged federal
6 predicate act violations herein, additional written and oral discovery will be necessary to provide all
7 details and to determine exactly what crimes were committed, if any. However, Remington has
8 hundreds of hours of surveillance videos, from several years, which provide the nucleus for many
9 future depositions. Maybe Gans and defendants have innocent explanations for some of their illicit
10 activities, and not everything alleged herein was a provable violation of federal law, but merely
11 violated county, natural and/or state law. In other words, as explained elsewhere, Gans criminal
12 enterprise does do some legal acts from time to time, and sometimes many of them in one day.
13 Also, as we have discussed, a mafia mob boss does not obviously and blatantly commit
14 ONLY unlawful acts ALL day, every day, 100% of the time. If Gans or the Godfather buys a
15 hamburger or a drink at McDonalds, that may be an innocent act, done merely because the
16 criminal was hungry, without any evil intent or criminal purpose or racketeering ramifications,
17 although if either of them used all or partially laundered money, it could be argued that virtually
18 everything they do is unlawful. Similarly, if a RICO member ate lunch in such a place that it would
19 infer a threatening, menacing or intimidating purpose, such as controlling the neighborhood or the
20 restaurant, then almost any relatively innocent appearing act could be construed as extortive, under
21 certain circumstances. Hence all details of time, place people present, circumstances and especially
22 purposes and effects of an Enterprises members on the plaintiffs or others involved, are all
23 necessary in order to determine whether an ostensible and likely predicate act really is such.
24 It is also conceivable that some of Gans racketeering activities, or possible purchases or
25 supporting endeavors, occasionally accidentally or randomly come down on the side of legality and
26 legitimacy, therefore, as above, not every Gans trip, act or phone conversation is necessarily
27 sinister, criminally oriented or related in any way to the Remington cases. If Gans has a wife or
28 children, and drives them to some sort of an activity, that might not be inherently unlawful, except

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1 to the extent that his car and gas are largely or partially paid for from laundered money derived
2 from his RICO enterprises income paid to him and to all his soldiers by Linda Lawrence.
3 24. Numerous specific Gans pre-trial hearing 1503, et seq pretrial lies,
4 mischaracterizations, perversions of justice, deceptions and frauds on the court, as cited
5 throughout this document.
6 In May-August 2016, Gans committed numerous provable and corrupt acts on the
7 stenographic transcript during the 90+-days of serious pre-trial deceptions, including without
8 limitation: Flagrant factual mischaracterizations; disingenuous, knowingly inaccurate and factually
9 false MILs; Admittedly, a few actually legitimate and mostly accurate evidentiary positions plus
10 many actual lies under oath, or when asked directly by the court to respond as an officer of the
11 court, wherein Gans supposedly must respond truthfully under his California attorney oath,
12 which candidly, Gans disregards and takes as lightly as though He was never under oath about
13 anything. All that has been explained in thousands of pages in the 200 MILs and elsewhere, and a
14 few of the more important ones are summarized in the next paragraph below. Judge Reinholtsen
15 presided every morning from 8:45 AM until 12 noon for 3 months, generating a massive but
16 expensive 250+ hour stenographic record, where Gans was sworn to be a truthful officer of the
17 court, but did not worry at all (then) about that being enforced. We will look at it as evidence in
18 this case.
19 Mischaracterized, misrepresented and/or LIED about (meaning false statements to a judge
20 by an officer of the court, but not sworn under oath) topics by Gans and Plot, included without
21 limitation: Mathsons twin 100 long 6 SOLID culvert, conduit pipes; Schwartzs misrepresented,
22 very late investigations, which never should have been have considered by any court; Multiple
23 (more than 20) deceptive, and grossly fabricated and misrepresented MILs; Legally improper,
24 incomplete, ONE-SIDED, bad faith FALSE case citations on all litigated topics; Repetitive,
25 incessant and deliberate prejudicial use of improper, illegitimate and irrelevant photos solely for
26 the purpose of prejudicing a jury; Repetitive use of biased out-of-time exhibits, which consisted of
27 using deliberately prejudicial 2011 photographs in bad faith to falsely simulate site conditions from
28 5 to 10 years earlier, which were knowingly (to Gans and Remington but not the court who allowed
them) almost 100% different; Said photos were surprisingly allowed by Judge Reinholtsen because
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1 he still negligently trusted Gans; BAD, knowingly improper and misleading SJIs were written by
2 Gans and then surprisingly accepted by the court; Improperly contacting and influencing
3 Remingtons trial witnesses, including Tidwell and Hoyos; and, eventually, in August 2016, Gans
4 coached and successfully got away with dozen hours of suborned perjury in five out of six of his
5 trial witnesses on the sole material issue to be decided by the jury.
6 Also, during this period, Plotz and Gans reinitiated their frivolous and extortive malicious
7 prosecution cross-complaint cause of action against Remington. Defendants bogus malicious
8 prosecution charges like there vexatious litigant charges were all DENIED in fall 2015 by Judge
9 Reinholtsen and Judge Watson. Clearly having zero factual and truthful basis, both above
10 extortive motions were obviously entirely unfounded and strictly in bad faith, under the well-
11 known facts.
12 Even after Judge Reinholtsen flatly denied them once again in late 2015, Gans reinstated
13 them all in DR140426 as a pure EXTORTION tactic against Remington in early 2016, again
14 attempting to make Remington cringe in fear and drop his just lawsuits against defendants.
15 Defendants malicious prosecution and vexatious litigant charges are so without merit that
16 they are trivial to defeat, and hence will be the subject of an easy 425.16 ANTI-SLAPP Special
17 motion, imminently. Remington has at least two attorneys in mind to bring these easy special
18 motions this time after defending two previously himself, in order to make sure substantial lodestar
19 attorney fees are awarded against defendants bad faith and corrupt extortive practices.
20 DR 140426 as been continuously stayed since that cross-complaint to the disappointment of
21 two different attorneys, interested in getting-in on anti-SLAPP motion attorney fees. HERE, they
22 appear to be a guaranteed easy, uncontested slam-dunk. That would be because: 1) Judge
23 Reinholtsen has ALREADY very recently rejected it; 2) the initial federal suit the subject of Plotzs
24 motion was fully approved, proof-read and initiated by an attorney, which means in other words
25 that under relevant case law, PROBABLE CAUSE was demonstrated by a skilled attorney in the
26 area, and the DR 140426 lawsuit was not some dumb pro per mistake, gone bad; and FINALLY
27 and probably most important: Federal Judge Vadas exhaustively examined and analyzed all of
28 Remingtons initial 2009 federal causes of action, evidence, and legal basis for several months. As
the record shows, he very easily and without any reservations whatsoever allowed Remingtons
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1 case to go forward, in a long and detailed ORDER. That is the very definition of probable cause
2 and there is no bogus, false (or any kind of) defendants argument or state court judge which can
3 review that evidence and conclude otherwise, and implicitly overrule a federal judge with
4 experience in the area, and considering the fact that said federal judge studied the case exhaustively
5 at the proper time, and ordered that it go forward. If attorneys and judges found probable cause,
6 who is young Plotz and lyin Gans to say probable cause was always lacking? It was always
7 there, the record shows it is STILL there, and but for Remingtons unfortunate Rule 26 disclosure
8 errors in 2011, plus Gans additional poisoning of Judge Vadas general attitude, causing him to
9 make a drastic Rule 37 (b) ruling, Remington presumably would have easily won that case.
10 In the overall corrupt PATTERN described in detail herein, of continuous, ordinary
11 unethical, deceitful acts mixed together with about 50% of actual criminal acts by the RICO gang
12 members, this frequently used effective extortion tactic by threat of a potentially fatally expensive,
13 bankruptcy causing possible rogue verdict from a malicious prosecution lawsuit, was a predicate
14 act, in Remingtons estimation. Not a HUGE, violent, murderous, catastrophic or egregious one but
15 another of Gans many extortions and Remington intimidations, intended to advance ALL the
16 enterprises objectives in one lawsuit, where THEY make HUGE money a second time off their
17 extremely profitable 1998 hazardous waste dump and its egregious contamination! What a weird
18 justice system where that is even conceivable, let alone much more than just possible! Probable,
19 may be is a better word because even today, defendants enterprise probably has a greater than 50%
20 chance of success, even in the face of a major RICO lawsuit, partly because the enterprises reach,
21 control, and putrid tentacles reach strongly and very confidently into all areas of power in Eureka.
22 When all this started, Remington was naive enough to think that this kind of a respectable
23 appearing RICO enterprise could not happen in America, despite the Godfather and other Mafia
24 films. Obviously, Remington has just led a sheltered life because organized crime is actually
25 everywhere if one opens their eyes and sees it. Even so, in idyllic rural Northern California,
26 previously it wouldve been difficult to imagine that someones gang could severely damage their
27 adjacent friendly and loving neighbors land, nearly destroy it over 10+ years with $600,000-
28 potentially millions of dollars of damages, and then trick, sue, harass, extort, intimidate, defraud
and swindle the poor victim as he gradually became too old to fully and ably defend himself!
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1 28. Larry Kluck, ostensibly in defense of RAO joined Gans enterprise in 2014 and began
2 minor unethical and justice obstructing acts immediately by mischaracterizing and
3 fraudulently defeating Remingtons Default Judgment attempt by falsifying filing dates and
4 intentions.
5 Although never fully clarified, inferentially Kluck was hired by either RAO construction
6 company, Rich Olson, or Olsons liability insurer. Discovery will be needed to figure that out
7 exactly. Olson and RAO were served with DR140426 in August 2014, and Kluck failed to respond,
8 answer or do anything more than just sit out in the Department eight (8) audience observing
9 Remington at several fall 2014 hearings where Gans or Plotz did all the talking for the enterprise.
10 Defendants deceit, illicit deceptions and pushing of Humboldt County judges and local
11 justice to their outer limits of patience and credence, began immediately.
12 The defeat Remington no matter what it takes enterprise described herein was fully
13 joined by Kluck and RAO in fall 2014, and KLUCK began obstructing justice from the very
14 beginning, with gross misrepresentations and lies about salient DEFAULT issues, deadlines, filing
15 dates, and what he did with respect to them. His hearing testimony on that matter made no sense,
16 was obviously self-serving, very incomplete regarding all of the details and exact timelines and
17 deceitful overall. The 10-20 page hearing transcript pertinent to that subject would need to be
18 ordered to prove any specific wrongdoing against Kluck, which we will consider doing if and when
19 he is named as a specific criminal (technically civil) RICO defendant. The details of Remingtons
20 attempted default judgment against REO which under the law rightfully could have or should have
21 been granted, took 10-15 pages to explain, in motion documents at the time, and are waived at this
22 time, here.
23 Not necessarily a federal predicate act YET, but a deft slipping through the cracks by Kluck
24 of the Humboldt County Courts file room and file stamping procedures ensued, leading to the
25 confusion of Judge Reinholtsen, or some sort of favoritism and very lenient application of the
26 default dating statutes to Kluck and RAO. After detailed discussions, an apparently narrow denial
27 of Remingtons default request ensued, since an answer, even if 3 months late, was evidently under
28 Department 8s interests of justice or judicial discretion umbrellas, especially when old, war-
horses like Kluck, that practiced law with Judge Reinholtsen 30 years ago were involved. Had
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1 Remington done what Kluck did NOT do and defaulted in effect, there is little doubt that
2 Remingtons case would now be OVER, but that is conjecture only.
3 What IS CLEAR is that from the first day Kluck belatedly began showing-up in summer 2014,
4 in the multiple Remington-Mathson Department 8 motion hearing audiences, Kluck conspicuously
5 and very frequently colluded publicly with the racketeering leader Gans inThe Humboldt County
6 Courthouses hallways, at least every few days in spring, summer and until September 2016,
7 Remingtons last courthouse visit and direct observation of their interactions.
8 29. Klucks Hobbs Act, 18 USC 1951 attempted extortion of Remington in late May 2016.
9 This additional act of extortion described below, occurred on a known May 2016 date, which
10 will be reconstructed and determined exactly from Remingtons detailed, extensive pretrial
11 memorandums, notes, evidence, transcripts and voice recordings, when he gets time during
12 discovery in this case to organize, collate and file said notes and evidence.
13 About 8:40 AM, Mr. Kluck saw Remington sitting alone, thinking and planning with great
14 focus as usual on the Department 8 wood bench, waiting for said Courtroom to be unlocked. Kluck
15 always watches Remington and carefully attempts to gauge his demeanor when they encounter each
16 other every few weeks, presumably so Kluck can evaluate and determine how Remington is
17 holding-up under and taking all this and to assess his personality stability and suitability as a trial
18 lawyer, what his seriousness level is about RAO, etc. Obviously there are plenty of variables for
19 Kluck to attempt to evaluate, as Remington does the same with him, Gans and all their witnesses.
20 We saw each other A LOT in 2016 as Remington had made a motion around March 2016 to
21 involve RAO directly in the May-August 2016 contamination trial, which never ensued, and Judge
22 Reinholtsen had DENIED that motion on tenuous appealable grounds. Remington has many
23 SCORES of other perceived errors to present when DR080678 next gets to the appellate courts.
24 In mid-May, Kluck walked-up swiftly to Remington, sitting as above in the Department 8
25 corridor to supposedly politely test him initially and to assess Remingtons nerves and capability
26 in facing the enterprise each day in Court.
27 On THIS day, after Remington passed the first test of fearlessness at facing Gans daily in a
28 REAL litigation, Kluck went further than his normal passive demeanor in order to SEND

404
1 REMINGTON A SLY, THINLY-VEILED MESSAGE that he was not just a passive, too old, lazy,
2 small town advocate, but was someone Remington should start FEARING.
3 Klucks words, in retrospect and in this RICO context, seemed intended to intimidate,
4 extort and/or scare Remington into giving-up before trial, by strongly, slyly and cynically
5 inferring Remington had no chance, against these slick highly experienced local trial attorneys.
6 His further inference was that, be glad we are NOT in this trial because well kick-your ass
7 (totally) when we are admitted as in DR140426. His exact words included something about maybe
8 youll win or MAYBE (AND MOST PROBABLY) YOULL LOSE (Lose had great emphasis),
9 seemed intended to infer that: Remington better give this up this deadly endeavor very soon;
10 Remington didnt really have a chance now; but, would certainly be routed in any case where (the
11 great trial lawyer) Kluck appeared; and therefore, prudently (and as per Klucks fatherly, helpful
12 advise) Remington should give up now, as he was obviously going to lose. The exact strange 2-
13 minute dialogue, odd-demeanor of Kluck and all his specific extortive words and meanings can
14 wait for discovery. But, as Remingtons attorney Harvey Roberts commented on this topic, Kluck is
15 just a (very) weird guy anyway, in a best case scenario, which is true, and hence Klucks
16 mannerisms, tempo and tonal innuendos were most of his message, going far-beyond the somewhat
17 menacing and un-hinged words, which could also be construed as being backed-up by Skillings
18 and Olsons known ruthlessness, ability and probable propensity to get their frontier justice
19 outside of the courthouse.
20 29A. 18 USC 1503, 1512, State and federal perjury statutes as proven during
21 discovery, John Mathsons major, incriminating errors in FAILING to consistently
22 regurgitate Gans felonious, perjured script about Remingtons TWO non-visits to Mathsons
23 land in 1998, plus some speculation on WHY Judge Reinholtsen inexplicably missed
24 Mathsons major errors, his situation and future role in these cases.
25 Gans chose Mathson as his lead perjurer because they talk extensively on the way to the
26 hearings, during all the breaks and on the way back to the office for a good 40-60 total minutes
27 every day; and, since Gans needed a lead perjurer and he was working extensively with Mathson
28 every day for at least five days per week, apparently Gans decided to try and give Mathson a shot.

405
1 During all of that conversational time Gans apparently felt Mathson had the mental capacity
2 and the motivation to learn the false facts Gans had written initially for Skillings and then to speak
3 and act them out on the courtroom stage, which John Mathson eventually did fairly well, until he
4 got tired one day and entirely reversed himself!
5 On that crucial day, when the judge should have stopped the trial and declared that
6 Remingtons position in the SOL trial prevailed a default, Remington and Gans caught all that of
7 course, but even with the transcript read it was too late to get the jury to buy into any of that
8 because they already concluded that Gans and Mathson were the good guys, here.
9 At that point, Remingtons best hope would have appeared to be the wise court who had
10 previously been thought to be very astute as to being a judge of character and testimony veracity,
11 and if so it should have picked up on that. But, here in Humboldt County in real life, the truth and
12 what was right, surprisingly to Remington at the time, did not prevail and/nor did he live happily
13 ever after, as he had actually expected. Instead, it was Gans and Mathsons gang that happily
14 congratulated themselves on their exquisite perjury, celebrated and even today going into 2017, the
15 Mathson-Kishpaugh Westgate gang members still congregate on Kishpaughs driveway usually,
16 glaring at Remington and plotting what crime against Remington theyre going to do next.
17 But, we digress, and by the time that Mathson got tired and forgot his entire perjured script
18 and blurted part of it onto the record, at which time the court very unfortunately adjourned the
19 proceedings. WHY?!
20 What happened was: Mathson suddenly got tired, reversed his position, and suddenly
21 reverted to the default position of HONESTY, because Gans lies had become too difficult to recall.
22 At that point, Mathson actually directly acknowledged that he had not walked the fill with
23 Remington, and that he never in his life has walked the fill with Remington but rather merely
24 heard it from some of his gang friends, Who in this case were in all honesty just Gans and his
25 coaching and his further 2016 discussions with Kishpaugh, Costa, Skillings, Joy Mathson, et al.
26 That is all that Mathson really he remembered, but why did the judge not immediately
27 pick-up on that and stop the trial and issue a directed verdict for Remington against the
28 Mathsons right at that point?
Remington wonders aloud today, what was that all about, and why at the crucial time when the
406
1 major lying witness suddenly began telling the truth did the court abruptly adjourned the
2 proceedings for the day?
3 Remingtons view, which undoubtably differs from Gans and the courts perceptions, was
4 simply that the court by that time, and on that roughly last day of testimony before closing
5 statements, was just going with an overwhelming momentum and avalanche of favorable rulings
6 towards defendants, and either just didnt give a damn about Remingtons case by that time, or may
7 have possibly missed the whole episode itself, were meant to biased in favor of mass and at that
8 point to understand its significance, but irrespective of all that, it was clearly inferentially too biased
9 against Remington by that point to care much. That especially applies to any evidence which
10 proved that Remington was telling the truth and the Gans-Mathson forces were lying, because as
11 Remington has maintained, throughout the trial, the court was kind, considerate, sensitive and
12 reasonable to Remington perhaps, but was entirely predisposed against him on every significant
13 evidentiary ruling, and also every insignificant one as far as Remington remembers today.
14 All of that material and a lot more was considered in some detail in Remingtons two
15 disqualification motions addressed at Judge Reinholtsen, which at this point have been denied.
16 Where the state cases go next in Humboldt County is unclear and will depend a lot on what
17 happens in federal court here. In any case, the inferences about this court and its evidentiary
18 rulings; its possible prejudice against Remington and/or bias in favor of Gans and his former law
19 partners; and the present merely circumstantial ties of the court to Gans, Brisso and their RICO
20 enterprise remains unproven, but it is hanging like a heavy, black storm cloud over these
21 proceedings now and is going to need to be investigated by Remington and perhaps the District
22 Attorneys Office over the next few years, and in any case considered by this federal court. Why or
23 whether Judge Reinholtsen is going to want to hang-around and be subjected to all, or any of that,
24 or why he would want to attempt to remain in this very borderline, and obviously corrupt Mitchell
25 firm- related unethical racketeering situation, on top of his already hyper-busy, almost crazy-
26 busy courthouse schedules, and anxieties about his own well-documented in the news press,
27 alleged written perjuries, remains to be seen and examined much more deeply if he does continue
28 on here.

407
1 30. Gans MAIN 18 USC 1951 extortion threat against Remington in mid-June 2016, in his
2 solicited main courthouse, second floor, middle-of-the-corridor meeting with Remington, during
3 our mid-morning break on an easily determinable exact mid-June 2016 pre-trial hearing day.
4 Here, Gans once again acted with clear malice, specific intent to induce Remington to act in a
5 specific manner which Gans well-new would quite predictably be fear, anxiety and/or possible near
6 panic, just as always occurred in these types of situations. As usual, Gans could always hope that
7 Remingtons health and emotional stability would eventually fail on some given day, and then
8 Remington would inevitably submit to his extortion, giving up his lawsuits and surrendering his
9 property in effect, with little and probably no compensation. As usual, Gans biggest sales pitch on
10 this and many other days, was for Remington to stop the pain, anxiety and avoid the fear and
11 substantial risk of being driven into financial ruin, likely bankruptcy and therefore have to give up
12 his entire estate, under the continuous, indomitable and infinite litigation pressures threatened by
13 Gans with continuing indefinitely.
14 As relevant background: this interaction was preceded by two significant and unusual
15 hearing occurrences, which provide context and probably the reasons why Gans accosted
16 Remington in the corridor a few minutes later.
17 First, Remingtons voice had just broken with emotion, and extremely rare occurrence, a
18 few minutes earlier during pretrial hearings, when he was explaining to the Court how hard it was
19 emotionally for him to keep opposing his former good friends the Mathsons in these proceedings,
20 for so many years. In that context, Remington had just spent a couple minutes explaining to the
21 court the kinds of sensitive, delicate feelings, fears and (some of Remingtons 2004) worst
22 nightmares, that we had shared for years in the mid-2000s; and second, the other immediately
23 prior context was similarly court room discussion with the court, wherein Remington explained to
24 said court the reasons WHY a lot of this time was being wasted because Remington believed that
25 defendants cannot and therefore WILL NOT TRY THIS CASE. The reasons Remington cited
26 then were because they dont have any experts left who are credible or who are willing to be
27 HUMILIATED now over their numerous blatant and material testimonial ERRORS, or who will
28 just totally disregard all truth and LIE for Gans in open court on the sworn record, and essentially
swear to any false, illogical and unscientific script that he writes for them. Remington at that time
408
1 therefore fully discussed and assumed that Ferriman and Gwinn were fully discredited, knew it,
2 were humiliated by it and were now apparently unwilling to follow Gans racketeering lies, as
3 discussed herein, in any case. If true, that left Gans with no environmental expert witnesses and
4 therefore no contamination trial defense whatsoever. Therefore, as inferred from the more than
5 three consecutive months of intense, daily pretrial hearings and about 200 motions in limine, Gans
6 had no substantive defense whatsoever, and therefore must defeat Remington on the numerous
7 technical and frivolous procedural grounds, which Gans has been using continuously now for many
8 years.
9 Seeing that Remington was somewhat emotional, distraught, the court considerately took our
10 midmorning recess, a few minutes earlier than usual.
11 About one minute later, after Remington came out of the mens room, Gans apparently
12 perceived some possibility of vulnerability in his prey Remington, and maybe some kind of a
13 chance to end all this, and so he signaled to Remington to come over for a chat, in the middle of the
14 corridor, after Remington had come out of the mens room.
15 For some reason Remington thought then that Gans was going to give-up then and there,
16 because he had no experts, hence NO defense in the contamination case, and the judge seemed to be
17 leaning Remingtons way that day. Apparently that lack of perception, incorrect intuition by both
18 parties in combination with the opposite objectives of both parties is one of the main reasons this
19 dispute has only escalated in the 10-years its been ongoing.
20 In other words, Remington was exactly WRONG as usual regarding Gans intentions or
21 possible honorable, just or even logical intentions or moves. Not surprisingly, it was also during
22 that general period, that Gans exposed his deepest corrupt and criminal thoughts and activities, and
23 completely went BAD about a month later, although that was not fully realized until Gans
24 surprise opening statement during the July- August 2016 trial, and then the depths of his desperate
25 and total racketeering criminality did not become clearly focused to Remington until several weeks
26 of thought about his two weeks of continuous multiple trial perjuries, afterwards, and in early
27 September.
28 Remington was kind of surprised at the HARD LINE Gans next took, the opposite of what
he expected then, but was perhaps understandable if Gans really does not have any environmental
409
1 experts for the DR080678 trial, and therefore must now tried to bluff his queen-high poker hand
2 into a winner. Apparently, all Gans now has left for his environmental expert team is only
3 Hillyard, who has never legitimately investigated Remingtons property, in reserve for FUTURE
4 other trials, as Gans recent actions seem to infer.
5 Gans said, angrily and emphatically: Youd better get out now, because we ARE going to
6 try this case and WIN... THEY ARE MAD.... Very mad and they will continue this with the
7 Mathsons until they WIN eventually after appeals (or whatever) and then they intend to sue you
8 for malicious prosecution (MP) and THEIR COSTS.. [Im just doing my job here, so dont
9 blame ME for this]. The THEY was greatly emphasized and to Remington inferred the Dark
10 Lord of Mordor (Lord of the Rings0 or the Evil Emperor from from Star Wars.
11 They intend to get their costs and attorney fees, which are quite HIGH (since 2008), no
12 matter what it takes.Remington was also given the distinct impression that Gans was intending to
13 use some or all of Remingtons trial witnesses against him, such as Tidwell and Hoyos, which
14 details emerged gradually, when Gans put one (Tidwell) or both of them on his trial witness lists.
15 This rapid, fast-talking entire 5-7 minute conversation takes at least 3-4 more pages to write-
16 out fully. But, it IS written-out more fully in Remingtons files, and will obviously be covered
17 exhaustively at the next depositions, i.e. of Gans next deposition, here. Remington believes that
18 courthouse encounter constituted Hobbs Act 1951 prohibited extortion, but Gans predicatively
19 will begin his additional cover-ups here with denials and a purported opposite opinion, so the
20 exact words transcribed and/or recorded at the time, his intonations, perceived meanings and all the
21 DETAILS, prior and subsequent context must be understood, sworn to and put on the record in this
22 case. In other words, he will be deposed on this conversation for at least an hour. Although Gans
23 multiple commissions of perjury in state documents, or his acts by a licensed attorney of merely
24 making false statements to a state judge probably are not federal predicate acts, YET, it is quite
25 clear that once serious discovery and sworn depositions of Gans and the other RICO defendants are
26 conducted, there will very quickly be federal perjury committed here, some of which will be
27 provable, especially after the first enterprise member breaks.
28 31. The MIL #20 ORDER, 1503, et seq. A strange event occurred on or about (an exactly
known day, clearly recalled hearing with many notes and/or recordings not presently transcribed or
410
1 available) June 2, 2016. what took place then can be (but has not yet been) exactly reconstructed
2 from Remingtons daily, detailed unorganized notes, his miniature recording device or from the
3 stenographic transcript when it is obtained. That strange event occurred on the exact morning
4 when the court issued its first preliminary negative, preliminary denial of Gans MIL #20, however
5 its enigmatic ORDER allowed Gans and Plotz to provide additional information in support of their
6 MIL #20, which they never really did, however a few days later mysteriously MIL #20 was granted
7 based on the odd occurrences of this day, approximately June 2, 2016.
8 Before the mid-morning break, The court allowed the parties to read his preliminary
9 lengthy MIL #20 DENIAL, but it was so uncertain and ambiguous that when we returned from
10 studying it, Gans began a rather masterful discussion saying that he was completely in agreement
11 with the court until the conclusion on the last page. When Judge Reinholtsen wholeheartedly
12 agreed with Gans that they really were not far apart at all and in fact in apparent total agreement,
13 they then had a SUPER-MEMORABLE (to Remington), momentous, rapturous rapport, and
14 religious -like coming-together in (the spirit of) Jesus moment. At that moment, as Gans and the
15 court were verbally and emotionally embracing each other, Remington felt and saw his entire
16 contamination case slipping away under Judge Reinholtsens shocking reversal of two prior rulings,
17 over a four-year period.
18 The court had evidently REALLY decided to GRANT MIL #20, prior to June 2, 2016,
19 despite initially appearing to do the opposite, and twice previously denying that collateral estoppel
20 motion at several year intervals. The court apparently found its out or legal justification for
21 doing what it had decided it wanted to do, but with no foundation in law, so it requested more
22 briefing FROM Gans, and specific written RESPONSES to four (4) courts questions, because it
23 clearly and emotionally had decided to go with Gans on gut-feeling and rapport alone, and was
24 seeking some kind of written cover for the appellate court, it appeared.
25 Thereafter, Remington wrote substantive rebuttals, and Gans and Plotz are unable to
26 properly answer any of the courts above four (4) questions, however after about a week of further
27 fiddling around, the court just granted Gans MIL #20, without getting any correct or substantive
28 responses to any of its four questions, in Remingtons humble and expert opinion.

411
1 At that moment, we now understand, and it was very clear THEN, also, Remingtons
2 entire contamination case was prejudicially decided by Judge Reinholtsen and essentially lost, as
3 relating to the major hydrocarbon and asbestos contamination posture/image it had justly
4 maintained since 2008.
5 It is presently undiscovered if Gans and Plotz just used false logic, personal charisma and
6 bad collateral estoppel arguments on Judge Reinholtsen or whether there was something more
7 nefarious or perhaps corrupt as inferred throughout these documents. Over about six months,
8 Remington has gradually concluded from intense study and scrutiny that Judge Reinholtsen was
9 more likely than not improperly influenced some other way as below. That error, if any, should be
10 easily overturned on appeal, should never have happened and cost Remington about 2 years in lost
11 time at a minimum counting the previous summary judgments and next appeal.
12 Gans or more likely Brisso is inferred to have possibly bribed Judge Reinholtsen, or rather
13 clearly to have somehow unduly influenced him, most likely by offering him post-retirement
14 employment perhaps, IF he crucially ruled against Remington on collateral estoppel. That quid pro
15 quo is Remingtons current operating theory, which has certainly not yet been proven and will be
16 difficult to prove until we get deep into sworn discovery in this case, and quite possibly not until
17 someone at the Mitchell firm breaks, and tells the truth about whats really going on here.
18 Judge Reinholtsens nearly case ending MIL #20 ORDER was a diametrical 180-degree
19 reversal of his previous estopped position maintained consistently for the previous 5 years! The
20 believed erroneous MIL #20 decision went against all influential case law, in Remingtons quite
21 studied opinion, and was sustained by NO known authoritative state or federal law from defendants
22 or the court, beyond an odd and legally WRONG interpretation of the Magistrates summary
23 judgment ORDER in 2011, and what facts he purportedly found, IF ANY, in his perfunctory and
24 technical dismissal of five federal statutory causes of action, due to the impossibility of providing
25 all or any of their elements without an environmental expert in the case.
26 The legal truth is that the federal magistrate court made absolutely no general findings of fact
27 when he granted Gans summary judgment against five federal statutory causes of action, and under
28 the controlling law if no definite findings are clearly articulated, then none have been made. If none
have been made, then none can be declared as the collateral estoppel basis of eliminating all of the
412
1 basic contamination facts in Remingtons state cases. To do otherwise was clear error, and
2 Remington expects to easily prevail on that and related issues in the Division I appeals court,
3 bringing the state cases back to a different judge in Humboldt County, if any uncompromised and
4 un-disqualified judges still remain here, which is presently in question.
5 Since we had not one but three environmental experts in the state case, none of the federal
6 courts reasons for dismissing Remingtons contamination causes of action were at all applicable in
7 state court. Judge ReinholtsenDoes not do science, has obviously had zero chemistry or physics
8 and as a result he just never fully understood pollution law. Nor could he determine what the
9 Federal Summary Judgment ACTUALLY decided, needed to decide or what, if anything, the
10 Magistrate actually determined relevant in state court. The reason that was difficult was because as
11 above, the magistrate never decided any issues at all beyond the fact that Remington could not
12 sustain any cause of action without any environmental expert witnesses admitted into the case. Said
13 Magistrate Vadas was not that wise or articulate either in his written summary judgment opinion,
14 which was highly subjective, nebulous and indefinite. In any case as a result of it, Judge
15 Reinholtsen abruptly REVERSED his 5-year position and not shockingly took the position of his
16 past and future law partners. The Court thereafter and contemporaneously said at least 5 times on
17 the record, maybe Im wrong but thats my position and you can appeal it.
18 Maybe Im wrong, to which Remington responded YES, I think you ARE and yes, I will
19 absolutely appeal. As explained above, Judge Reinholtsens opinion was based on NO substantive,
20 relevant collateral estoppel case law or serious analysis from anyone, and came after he had
21 consistently decided the opposite way TWICE, over 5 years of analysis and several thousand pages
22 of argument beginning in 2011 and mostly being decided in 2014. Remington provided him with
23 several hundred pages of definitive collateral estoppel philosophy and opinions based largely on the
24 very authoritative Walter Heiser treatises, however said judge dismissed those treatises as being of
25 no interest. At the time he said, there are lots of treatises on collateral estoppel. Obviously that is
26 true, but Remington has not seen any that were clearer or more comprehensive in their relevant
27 coverage and in-depth Supreme Court case studies than Heisers work.
28 Whether this eventually proves to be 18 USC 201 BRIBERY or merely more deceptive,
tricky and/or erroneous litigation tactics, obviously remains to be seen. Judge Reinholtsen in any
413
1 case does not appear to really be up-to-speed on this scientific case, and clearly just does not have
2 the time or enough quickness and brilliant intellect of a US Supreme Court Justice to decide these
3 rather complex legal issues and authorities, Especially while attempting to adjudicate at least 100-
4 200 other major litigations and trials. Remingtons prior experience in San Francisco federal court
5 is that most Federal judges appear to have a better capacity to FULLY research and REALLY
6 understand the facts and law here, probably have more time to meaningfully focus and get to the
7 heart of the matter in a few hours after that focus, and are also not preoccupied with 100-200 other
8 cases, as state Department 8, now transferred to Department three, in Eureka is. A pro per, even a
9 very good researcher just could not compete with at least two old and future very long-time friends
10 and Mitchell firm law partners, inferentially, and so far has failed on this bogus and imaginary
11 collateral estoppel issue, certainly.
12 Possibly, the Honorable Judge Reinholtsen just committed innocent error and none of this is
13 relevant to RICO conspiratorial enterprise. Well know when or if Judge Reinholtsen is fired for
14 ethical irregularities and embezzlement from the state for his pay check and declaration
15 irregularities in crimes, related to the lengths of time his cases have been open. OR alternatively,
16 perhaps we will not get to the bottom of this anomaly until 2019 when Judge Reinholtsen will be
17 retiring for GOOD. If he goes back to the Mitchell firm THEN, that will be taken as proof of these
18 allegations and proof that his declaration opposing disqualification was disingenuous or worse. This
19 precise issue and what everybody has sworn to so far, will not be forgotten here by 2019, and at the
20 rate we have been going, our investigations will still be under way at that time.
21 32. After June 2016 and for the next 3 months (and to date) Judge Reinholtsen has seemed
22 to be 100% under the influence of the Mitchell firm, inferring to Remington some form of
23 prejudicially strong influence and/or 201 bribery, otherwise the pretrial evidentiary decisions
24 would be closer to 50-50 or 60-40, as they were here for at least seven consecutive years, but NOT
25 99-1, AGAINST Remington, which began in about April 2016, but became insurmountable he
26 prejudicial from June through September 2016.
27 From that very day forward, we are calling it June 2, 2016 for now, and for about 60
28 consecutive days thereafter, Judge Reinholtsen further confirmed defendants undue extralegal
influences, by thereafter DENYING about 100/110 important Remington SJIs, 95% of
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1 Remingtons most important evidentiary issue requests, at least 170/180 crucial Remington MILs
2 on all relevant trial topics (from the Renz damages period to Gans demonstrated ethics and truth
3 violations, which Judge Reinholtsen not only loudly ignored, but eventually stated that he didnt
4 want to hear), without granting a single significant Remington MIL or evidentiary request. Many
5 scores of examples exist, including without limitation: Remingtons 2016 discovered photos taken
6 in 2003, which importantly REFUTED 100% of Skillings perjured testimony were crucial, and
7 would have begun a flood of total rebuttals of ALL Gans suborned perjury in five (5) interlocked,
8 100% COACHED witnesses. Judge Reinholtsens DENIAL or REFUSAL of about 90% of all of
9 the evidence Remington offered for trial, and even WORSE his GRANTING of 75% of what Gans
10 offered, including DOZENS of entirely blatantly prejudicial photos with no just probative value,
11 GUARANTEED that the jury was mislead and prejudiced. Gans photos were ALL from his
12 frivolous offensive case No. DR080669 and all those photos were prejudicial, biased and cleverly
13 and aptly INTENDED to inflame a jury.
14 Also, the SOL case was about conditions in 2006 or earlier. We seemed to agree
15 philosophically at one point in pretrial hearings that any photo taken AFTER that was immaterial,
16 usually prejudicial and overall irrelevant and hence an admissible.
17 Nevertheless, the Court disregarded all of those obvious and just evidentiary principles and
18 admitted all 50+ of Gans irrelevant and prejudicial photo exhibits, ZERO of which were from prior
19 to 2006, and therefore not one should have been admitted into the SOL trial. That issue will also be
20 appealed
21 Remington had dozens of pre-2006 photos, but 95% of them were BARRED by the court as
22 cumulative, Improperly disclosed and/or irrelevant, yet NO specific REASON was provided by the
23 court for most of his decisions, and as many as 100 in a day appeared to be arbitrary, prejudicial and
24 just wrong!
25 Also, Judge Reinholtsens perceived BIAS, appeared to be PROVEN again, when he
26 approved ALL of Gans extremely simplistic, incomplete and legally erroneous SOL instructions,
27 and prejudicially DENIED ALL OF REMINGTONS which were crucially relevant and pertinent
28 to the discovery of subterranean damages and what visual facts puts a litigant reasonably on notice

415
1 to investigate the causes of his damages, when said damages are below ground, entirely concealed,
2 and therefore totally unknown. Another appellate issue we will not belabor here.
3 Also extremely prejudicially, said Judge critically barred Remingtons needed case-saving use
4 of Gans 2011 Special Interrogatory #2. That special interrogatory alone could have changed the
5 outcome of the case, had the court permitted its proper use and submission to the jury, and acted
6 itself like that document had some merit and importance. When the court objected to its use in
7 general minimize that, the jury turned off and dismissed it entirely.
8 Those and numerous other related court rulings, which Remington regards as error, insured
9 that Gans improper Voir Dire remarks were irreparably and irredeemably biased against
10 Remington, and amounted to nothing less than the courts full acceptance and condoning of Gans
11 entirely improper and illegal witness preparation and coaching, which illicit acts Gans even
12 acknowledged before the trial started, and during the trial Gans definition of coaching was
13 actually defined as writing false scripts and suborning perjury.
14 Gans even emphasized this witness coaching in every discussion he had with every juror
15 during Voir Dire, and made it his main theme, so that the jurors would not hold the fact that he had
16 coached his witnesses against him or his client. One by one, each juror agreed to that contract
17 and Remington who was conducting his first Voir Dire and jury trial did not understand the
18 fraudulent significance of those questions, or the diabolical and fatal ramifications of that
19 illegitimate contract until after the trial.
20 Basically, no juror could join the jury in good faith without first accepting Gans statement
21 that he had coached all his witnesses. Witness coaching and overt, admitted wood shedding is a
22 serious violation of attorney protocol worldwide, and should have been stopped at the onset.
23 The court should have interjected with how improper that was the first time Gans said it, and
24 then stopped him completely the second time Gans did it, however the court evidently obviously
25 accepts coaching and the suborning of perjury, which is what occurred here. Other catastrophically
26 prejudicial rulings by Judge Reinholtsen, against Remington, during the trial and both pretrial and
27 post-trial, included, without limitation:
28 1) No Remington amended complaint was allowed by Judge Reinholtsen despite 8 years of
continuous, sworn and documented gigantic case fact refinements, variances and changes,
416
1 including the crucial statutorily allowed and demanded election of whether to properly allege
2 permanent or continuing nuisance/trespass after discovery had ensued and therefore based on the
3 actual facts developed. Remington had until the trial date to make that election of continuing
4 nuisance and trespass because all proofs dictated that the contamination was remediable, and
5 therefore Remington had properly made said election way back in June 2011, about two weeks
6 before a scheduled trial then; 2) No deposition of Gans star witness Morgan Randall was
7 permitted during the pretrial period. Gans refused to disclose the substance of his testimony and the
8 court refused to do anything about that or allow Remington to learn anything about his testimony
9 by any written or oral means; 3) As above, no admonishment was EVER made against Gans
10 prejudicial trial practices, about coaching, about suborning perjury in all his witnesses, or about
11 the misuse of Remingtons improperly transcribed, prejudicially improper, contested, uncertified
12 Conn-deposition, which Remingtons attorney had demanded be retaken or voided entirely; 4)
13 Remington was very improperly barred from any mention of asbestos or pollution, because even
14 after approval of MIL #20, denying all mention of any pollutants or any asbestos, etc. in a
15 contamination case, was clearly error and not even the federal magistrate inferred or intimated
16 anything that draconian, in any way, neither in his dicta or his orders; 5) The court should have
17 barred 90% of Gans flagrantly prejudicial fence and aerial photographs in the 2016 SOL trial, and
18 just had no recognition of the impact of Gans bad faith use of said obviously prejudicial and
19 irrelevant photographs, and if he did, it inferred he was trying to get rid of Remingtons case
20 prematurely; 6) The scheduling of a DISMISSAL hearing 10 days after trial without any proper
21 Opposition time for Remington, was obviously intended to be crippling, and directly led to
22 Remingtons rejected disqualification challenges; 7) Disallowing Remingtons 2003 photographs
23 which impeached all of Skillings testimony 100% was a crucially crippling prejudicial ruling. They
24 were taken in the exact time period at issue, were among only 5-6 such photos out of the hundreds
25 that were discussed and offered, and they absolutely should have been allowed to impeach
26 Skillings perjured testimony, if not for all purposes; 8) Even in February 2017, Judge Reinholtsen
27 never allowed written opposition motions to Gans post-trial brief, and solicited simultaneous
28 motions which basically were independent of each other without addressing the proper issues.

417
1 Remington made an elaborate oral presentation, reading from the relevant controlling Supreme
2 Court cases and defendants own statements about them over the last year, on February 17, 2017
3 about where DR 080678 should go next; but, Judge Reinholtsen is not familiar with the appropriate
4 law and whether he will become so before he rules on that case and sends it to the appellate court, is
5 presently unknown, ETC.
6 33. Interstate money laundering, violating 18 USC 1956 and 1961-1964, et seq. was done
7 by all defendants, as they all bought RE and merchandise with illicit income derived from
8 these alleged conspiratorial racketeering activities.
9 Linda Lawrence, allegedly on behalf of Allied Insurance Company, financed this entire illicit
10 extortion racket partially from premiums gained from the Mathsons (and possibly also from RAO),
11 and therefore all of Gans RICO enterprise financing was directly based upon the 1998 illegal
12 hazardous dumping schemes, where the Mathsons received at least a $150,000 financial and real
13 estate benefit.
14 Separately, as will be fully developed in discovery, RAO, Skillings, Olson and their related
15 presently unknown other DOE defendant subcontractors and employees, also greatly benefited from
16 their collective criminal schemes throughout the last 15-20 years. Therefore, as we will prove after
17 considerably more discovery, RAO and Olson have built somewhere between at least $1-7 million
18 worth of Southern Eureka suburbs real estate primarily using unjust profits, elicitly gained drug
19 trafficking funds and other unlawful and/or racketeering income based on their illegal dumping,
20 hauling and disposal practices over many years, and perhaps derived from many other unlawful
21 activities which have not been discovered yet. Since most of the above referenced illegal RAO
22 hauling a disposal crimes presumably did not involve Remington, they would need to be sorted-out
23 from Gans RICO enterprise which only had the specific objectives named and only related to
24 Mathsons and Remingtons properties as described. This may get quite complicated because RAO
25 presumably had some legitimate interests, construction projects, perhaps ordinary bank loans, some
26 concrete construction contracts and possibly even some honest real estate developments which were
27 partially based on legitimate funding and partly based on illegitimate laundered funds in a presently
28 undiscovered proportion. We dont know today, but we intend to find out.

418
1 Remington here in this RICO statement is only concerned about Gans alleged and described
2 RICO enterprise which affected and seriously damaged Remington and the Burl Tree, however
3 when the district attorneys office, US Attorney or other federal investigatory organization gets
4 involved in these matters, they would presumably have different objectives and seek to investigate
5 all types of RAOs illegal activities in a much broader sense. Hence their services and investigative
6 resources will be invaluable here, and it will be up to Remington and this court to thereafter fairly
7 sort-out what RAO and Olson did to further Gans racketeering enterprise and what RAO ALSO did
8 that was illegal, but prior to Gans and Remingtons involvement and hence independent of this
9 RICO case.
10 All unjustly derived income and/or other monies derived from said above-described, illegal
11 racketeering activities, related cover-ups, bribery and extortion, received within the last four years
12 or other unjust riches saved from prior periods and/or invested, spent or otherwise used or invested
13 within the last four years, that was thereafter distributed to and from all the RICO lawyers, experts,
14 insurance companies and other participants here, which was then passed (or went) into interstate
15 commerce during every qualifying trip and/or purchase by anyone on defendants litigation team,
16 would become subject to this statute.
17 As we just said, discovery is needed here to PROVE all exact details here, but there can be no
18 doubt that considerable and important money laundering has widely occurred here over the years,
19 amongst these enterprise defendants and members. In the Remington/Mathson related Gans RICO
20 enterprise an estimated $1-2 million dollars of illicit racketeering gross revenues, with a substantial
21 but less net profitable income, was generated initially and then used for major residential home
22 building and all the ordinary expenditures of this 35-50 member criminal enterprise. The Mathsons
23 also spent huge amounts of money remodeling, renovating and rebuilding their entire property
24 DIRECTLY after and directly derived from their illegal financial infusions in 1998; RAO is known
25 to have built a large quantity of nice individual residences, and at least 10-20, along Walnut Drive at
26 Northridge Drive, and also all-over other parts of Cutten, CA; Gans, Randall and Nelson are also
27 believed to have built or developed major real estate during this period, and likely many of the other
28 enterprise members, to be discovered in the next several years.

419
1 34. BRIBERY, 18 USC 201. Gans, using Allieds unlimited money bribed all Gans
2 coached trial witnesses, and quite probably the at least one file room document saboteur,
3 and inferentially others in the courthouse.
4 Bribery here is defined as: Gans and his co-conspirators and other named top RICO
5 enterprise leadership paying money to his informers, agents and most especially to all of his trial
6 witnesses, usually at 2-20 times what they were worth in the local market place for their hourly
7 labor. Costa and Kishpaugh may have been paid more than 20 times there nearly 0 value in the
8 local workforce. Bribery, in the sense plaintiff uses it here, means: Gans paid substantial funds to
9 a variety of his witnesses to alter their thinking, behavior and to completely change and/or strongly
10 influence what would ordinarily have been their honestly recollected trial testimony, to be
11 intentionally untruthful and false. In this RICO organization, the price of perjury is very cheap.
12 Gans clearly has only one criteria with his trial witnesses and truthful testimony is not
13 involved. Gans requires his witnesses to testify only to EXACTLY what Gans writes in their
14 scripts, which are always mischaracterized and based on false facts or worse. Once Gans witnesses
15 have been fully indoctrinated, wood-shedded and improperly given the speech (all
16 intensely in absolutely direct and prosecutable violation of California attorney ethical codes) about
17 how Remington caused all evil in this community, continues to do so and absolutely must be
18 stopped at all costs, and therefore is similar to, or IS the devil incarnated; NEXT, they are coached
19 and thoroughly rehearsed as needed in all of the arts which are needed to absolutely refute and
20 crush Remington. That is exactly what Gans did in July- August 2016, prior to and during the SOL
21 trial.
22 For example, BOTH Kishpaughs, BOTH Mathsons and the elderly, ex-pulp mill janitor
23 Costa are worth almost exactly ZERO dollars per hour on the job market, and presumably would
24 ordinarily not work at all, especially for under a dollar an hour. They are all disabled, retired,
25 unemployed, for good reasons, and those four are all very obviously unemployable by anyone for
26 anything. However, that group were generally paid $100/hour, probably largely under-the-table
27 or more for performing their memorized Gans written trial play scripts. The Mathsons received
28 even more per hour since they received the above-described (self-serving, for Farmers Insurance)

420
1 $20,000 bribery, extortion or protection, from GANS, payment, for only what appears to have
2 been about 100 hours of coaching and memorization of false testimony time.
3 On the other hand, Gans two other witnesses Skillings and Pulley ARE young enough and
4 energetic enough to be worth something, perhaps quite a lot, on the Eureka job market but they too
5 also are believed to have received 3-10 times their actual market worth, for their few minutes of
6 trial time, as a BRIBE by Gans, to keep them happy and to make sure they always show-up.
7 Said needed exhaustive Discovery will reveal the actual dollar amounts paid to Gans
8 perjuring witnesses, and the evidence of being paid by check will be sought, however witnesses like
9 Skillings who operate in the CASH economy may never be properly authenticated. Our previous
10 nine years of experience here has proven to Remington that defendants never release any financial
11 information voluntarily, especially if it is deleterious, so many motions to compel our anticipated
12 here, unless this Court just gets angry, serious and intimidating enough to where Gans RICO
13 enterprise surrenders everything voluntarily or just crumbles.
14 It does not take much money to pay Kishpaugh to lie for his friends the Mathsons, especially
15 while his house is in foreclosure as it is today, and thereafter WAS foreclosed. Also, today on
16 plaintiffs way to the office he noticed an unusual number of cars parked in and near
17 Kishpaughs driveway and alleged drug distribution center. However, both Kishpaughs MAY
18 want to recant their previous testimony and DISAPPEAR here, if it looks like Gans or ANYONE in
19 this enterprise is going to swing and/or do JAIL time, because THEN ALL conspirators are
20 susceptible to just punishment, especially those who have BLATANTLY committed obvious perjury
21 on the stenographic record or other provable predicate acts.
22 If Remington were an enterprise member, he would be especially concerned about Joy
23 Mathson and her occasional propensity back in her 2010 deposition by Harvey Roberts to
24 intrinsically appear to want to tell the truth and to often do it by accident and/or kind of put her
25 foot in (her and Gans) mouth, so to speak. Here, it is very likely that during a two-hour deposition
26 she would inadvertently tell the truth about what she knows of the RICO enterprises crimes which
27 are encyclopedic. Can she keep the truth from blurting out?
28 Also, If SHE prudently and intentionally decides shed rather TELL THE TRUTH than risk
going to jail, for failing to be brilliant enough to memorize all the false testimony that Gans has fed
421
1 to the Mathsons, that may well bring down ALL the dominos, sooner rather than five years from
2 now! Joy Mathson is somewhat different than any of the other known RICO members, in that she in
3 the past has appeared to try and tell the truth at times, and she appears to think that everything that
4 she does say is the truth, even when shes factually mistaken, which is often.
5 In this case, she now knows that John Mathson and the others named committed perjury
6 about whether Remington ever visited their property in 1998. She also claims that she knows and
7 recalls in detail what Gans has now told her that John Mathson came and told her in 1998,
8 although she has no first-hand knowledge of anything. We will be spending a few hours on that as
9 to what she honestly remembers, versus what Gans told her to recall and then testified to under
10 oath.
11 There was no doubt from her cocky look and massive amounts of notes she carried-around
12 with her four days in August 2016, that she was fully prepped to lie for Gans and the others
13 complained about herein. However, she got really lucky and was not called as a witness and she has
14 not yet committed any trial perjury, but does she STILL plan to, when the stakes or penalty for
15 making a major error are federal prison? Thats one of the first things we will need to find out at her
16 next deposition as to what her posture going forward is going to be whether truth or perjury. John
17 Mathson has buried himself completely and now must continue with his perjury, and Joy Mathson
18 his wife will make every attempt to support that, but will she be able to if she sees some of the
19 dominoes falling? Will she implicate herself now in federal perjury with very severe penalties,or
20 just honestly plead insanity that she doesnt really remember anything, not even what Gans told her
21 to swear to?
22 Hopefully, she will take this fortunate and golden opportunity to avoid federal perjury, and
23 explain what she really remembers from 1998 if anything at all, however that will very soon be out
24 of Remingtons hands. Plaintiff has seen a small amount of good emanating from her many years
25 ago and the only real question now is whether that has all been snuffed-out in this avalanche of
26 SOL trial perjury suborned by Gans RICO enterprise. Remington still has a small soft spot in his
27 heart towards her because SHE was the one who honestly turned-in her friend, the contaminating
28 and lying CROOK Jon Kishpaugh, around 2003 to Remington when he was investigating who had

422
1 broken down his fence and done a large amount of Escallonia clippings dumping into his
2 upper ravine posted No Trespassing and No Dumping.
3 Which neighbor had the audacity to tear down Remingtons simple fence in those days and
4 violate those signs? Joy Mathson knew and had witnessed it, and she did her neighborly,
5 motherly and responsible duty in informing on her friend in a subtle way, to her good neighbor
6 Remington, by not naming anyone directly but telling Remington whose yard to look for what
7 evidence in, which he did successfully. That was all pretty tricky, pretty clever and very honest and
8 forthright at that time around 2004, but probably all of those traits have now been lost. All that and
9 much more has been fully explained in writing elsewhere and will be addressed again in detail at
10 the next trial.
11 Joy Mathson can never tell the FULL truth here now, because she knows enough to put
12 Gans, John Mathson, Kishpaugh and probably 4-5 others in prison right now but possibly she
13 could take the Fifth Amendment and somehow avoid going-down completely in the John Mathson
14 and Russell Gans hopelessly leaking and sinking RICO ship. She would be a great place for the
15 district attorney to start questioning, because she is not a pathological liar, possibly still prides
16 herself somewhat on being something of a truth-teller, and may be smart enough to avoid
17 committing federal perjury charges to investigators while protecting her husband, the felonious,
18 vandal, perjurer, evidence-spoiler and criminal John, and if so, very obvious inferences about
19 the truth of what the enterprise has been doing will become evident, quickly and easily.
20 Plotz, Randall, Costa, Evans, Hilfiker and even BOTH Kishpaughs when PRESSED may
21 decide to save themselves, and for example, will Mickee Kishpaugh back-up her husband under
22 penalty of federal perjury charges, or potentially drown with him? She knows exactly what the truth
23 is regarding ALL the defendants contamination crimes and their discovery, and she has known
24 about everything for many years and when district attorney investigators interrogate her what she
25 does or says will be of great interest.
26 Just as Gans took all of the contamination case matters out of John Mathsons hands in
27 December 2007, this RICO enterprise investigation will probably be largely out of Remingtons
28 hands rather soon, also. Hopefully, shortly Remington can just tell the truth about what he knows to
his lawyers and to district attorney prosecutors to deal with or to potentially ignore, if the case is too
423
1 expensive to prosecute or lacks subject matter of current prosecutorial interest. With the many long
2 Gans-based chains of perjury now in the sworn stenographic record, it should be easier to unravel
3 all of these disingenuous strands of testimony, than when it was just hardened, life-long
4 pathological LIAR, John Mathson.
5 With at least scores of federal predicate acts and well-over 100 state and county
6 misdemeanor and felony violations provable here, once sworn denials are put in the federal
7 discovery and trial record, there will be enough federal prison-time here to go around to ALL
8 named defendants, but with 35 or more co-conspirators, some of whom are obviously much more
9 guilty than others, there may be some prominent names on these lists who may want to avoid
10 becoming federal felons, at this young age.
11 Ryan PLOTZ comes to mind, initially, after Joy Mathson. He has been observed to not
12 always be obviously on the same page as Gans, and Remington could document how and where
13 that might be, IF he came forward quickly with the intention of TELLING THE TRUTH about the
14 2016 suborning of perjury, which inferentially he OPPOSED, and which it is conceivable that he
15 may not even be a part of28, according to Discovery. A couple truthful whistle-blowers to implicate
16 Gans would no doubt garner immunity with criminal authorities and would streamline this whole
17 prosecution of Gans collusive, unlawful RICO enterprise.
18 Additionally, BOTH Mathsons were essentially BRIBED under Remingtons definitions and
19 understanding of the justice code by the payment of $20,000 by Gans (via Farmers Insurance)
20 to them for their testimony and silence about all this. Gans creatively developed their frivolous
21 bogus lawsuit against R for visual nuisance and totally convinced and sold Farmers on its
22 veracity, given the witnesses on both sides and Gans incredible fraudulent advocacy abilities.
23 Harvey Roberts was NOT sold but knew that a jury might be and Mazie Klein (Farmers claims
24 rep) also concluded that Farmers had possible exposure and litigation costs here in partnership with
25 Remington of potentially $2-300,000, or more, or LESS, but in any case MUCH MORE than
26 $20,000. Therefore, Gans played on the fears of Mazie Klein and deftly extorted $20,000 from her
27 for the purpose of getting Harvey Roberts out of the case, who was providing great assistance to
28
28 Plotz might even consider coming forward informally to someone, such as Remington, or through
his own attorney, or the District Attorneys Office, requesting some sort of leniency or whistle
blower status, if it happens quickly. Otherwise he is guilty of federal mail/wire frauds TODAY.
424
1 Remington for many years, and to avoid having to defend potential future punitive damages and/or
2 malicious prosecution causes of action29. After Gans extorted the $20,000, he paid it to the
3 Mathsons essentially as a bribe, because arguably and rightfully it could have gone to Allied
4 insurance as a partial reimbursement of their estimated $250,000 in defense costs to date.
5 Mazie Klein and Farmers were smart. By being extorted, and assisting with the bribing of
6 the Mathsons, Farmers already has saved MUCH MORE than $20,000. Klein effectively through
7 Remington under the bus as far as their providing Roberts defensive services and discovery cost
8 assistance. As above, there is no doubt that they saved themselves an incredible amount of money
9 and the impact on Remington is presently unknown, but it is certainly less advantageous than
10 formally when Farmers was providing a defense, but only a defense to a case which no longer
11 exists.
12 The above-named witnesses testimony was KNOWN by ALL to be FALSE, not just partly
13 false but ENTIRELY FALSE and the opposite of the truth Remington presented.
14 Even Pulley, the only mostly honest witness Gans called, was thoroughly corrupted by, you
15 guessed it, in his survey map drawn in 2011 to support his declaration based upon Gans initial
16 unethical requests. He acknowledged the truth of all that that in 2016, however, and avoided any
17 substantial embarrassment or perjury, accordingly, so far.
18 In fact, nothing Pulley said at the SOL trial was objectionable as related directly to this RICO
19 cause of action, nor was any of the specific testimony by Mathson or his supporting perjurers
20 relevant here or a predicate act. On the contrary, this discussion, on page 409 under RICO
21 statement #34 is an additional discussion of Remingtons complaints about Gans corruptly bribing
22 his witnesses by overpaying them for present, and in Pulleys case, FOR future false testimony, but
23 these complaints have nothing to do with the substance of their testimony which would be protected
24 by CCP 425.16 and by the litigation privilege to some extent.
29
25 The pretrial proceedings alone lasted about 150 days, cost Allied Insurance about $200,000 and
are FAR from over. They are not even one FOURTH over. Had Harvey hung-around every day for
26 all that, say 200 trial and hearing days, plus travel motels, etc, of say only $500 per day, thats still
27 over $100,000 before transportation, expert, witness, exhibit, etc costs of MUCH more. Thus,
Mazie Klein and Roberts were SMART. Bribing the Mathsons through Gans saved them at least
28 $150,000, before any verdicts and probably over $350,000! So, BRIBERY pays, across the board,
and in any event OCCURRED HERE, and at a cost to Remington, approximately proportional to
the savings by Farmers, Gans and Mathson.
425
1 The scope of Gans intended future testimony for Pulley, as with all his witnesses, went FAR-
2 BEYOND mere TRUTH, his surveyor skills and work, and in the future, including the contamination
3 portion of this federal case, Pulleys bogus site plan which has been used by both parties at trial
4 further helped to advance Gans general expert conspiracy, by knowingly, grossly and materially
5 understating defendants contamination VOLUME, by 5-10 times! That was reflected on Pulleys
6 map as a gross lateral area understatement of FOUR-FOLD, which multiplied by 3-4 MORE entire
7 areas (length x width), when depths are multiplied by areas to get volumes, sets the stage for
8 OTHERS to build on Pulleys Gans drafted DECEIT.
9 Although not especially relevant here, what Remington is rather in-artfully attempting to say
10 above is that a fourfold error on Pulleys map multiplied by the equally significant 3-400% overall
11 gross understatements in Gwinns depth measurements, which are used in defendants overall
12 volume of field calculations, immediately leads to a total error of 12-1600%!! Pulley is on
13 record as intending to aid and abet that egregious and fraudulent error, which is much more than
14 just an innocent arithmetic error. However, Pulley did not swear to the truth of any of those
15 measurements during the 2016 trial, and therefore committed no perjury YET. As a result, this
16 discussion is about the future only and is not an improper or unlawful attempt to sue or charge
17 anyone of wrongdoing or of a crime, because of testimony they rightfully and constitutionally made
18 in a public courtroom proceeding.
19 In other words, to his credit, in the 2016 SOL trial Pulley did not (yet) do any of the lying
20 required by Gans in the contamination trials based on the fraudulent data, but Ferriman and Gwinn
21 have been committing the next required fraudulent RICO step, in their 2011 sworn declarations.
22 Perhaps Pulley got lucky on his direct examination so far, because the topic of the veracity of
23 his measurements never really came up initially, so Pulley never had to defend his area dimensions
24 on the map, except when Remington inquired about it on cross examination in a context where they
25 were not especially relevant. Therefore at that time, Pulley merely said that John Mathson told him
26 where the fill was and Pulley just sketched-in what John Mathson falsely told him, which is not
27 wrongdoing by Pulley because he was honest about what he did and where he got his data. Gans
28 and defendants are expected to capitalize on Pulleys strong voice and to a juror that infers or
implies honesty, and it worked in August 2016.
426
1 Pulley is nearly credibility and apparently or at least inferentially to a jury possesses
2 solid honesty, but only AFTER his map notes are thoroughly analyzed as to who wrote them,
3 who provided the actual numbers (Gans through his puppet Mathson), and WHO ordered them put
4 on his main top few map (Gans). As above, Pulley appears to be worth about a maximum of $100
5 per hour, and was not asked about his pay rate at the recent trial, but we will be discovering that in
6 the future to make sure his pay is reasonable also and not in the bribery range. Pulley is believed to
7 have been paid several hundred dollars per hour for his trial testimony, which certainly borders on
8 improper influence if not bribery.
9 In summary, all participants in Gans defense are believed to having been paid MANY
10 TIMES what their time was and still IS actually worth, if one stipulates that no opinions are being
11 improperly BOUGHT, on the Eureka job market, as above. Future discovery in this case will
12 focus strongly in this area. When 5-9 dollar per hour employees are surprisingly paid $100 per hour
13 that immediately arouses suspicion. Gans gross excessive monetary payments in themselves are
14 the very definition of bribery, as he is here getting an unnatural and untruthful result by paying-off
15 5 or more witnesses worth nothing as employees, with the possible exception of Skillings, as noted
16 above, assuming that he is not fully disabled.
17 Also, Esko, Martel, Reinholtsen (inferentially offered a place to retire shortly), Randall,
18 Kishpaugh, Nelson, the file room spies and saboteurs, and the others cited, etc, are also believed to
19 have been bribed with money, or very strongly influenced with something else of value to them, as
20 we will now begin investigating aggressively and demonstrating in Discovery.
21 35. Gans extortion of Remington on May 26, 2016 with Morgan Randall, 18 USC 1951.
22 Gans intentional extortion of Remington by maliciously withholding the specific content of
23 Randalls imminent trial testimony in May 2016, was highly damaging, prejudicial and invoked
24 substantial fear because it was then believed on that day, to be only a very few days before trial.
25 Remingtons rather angry reaction to set extortion was brought into the court room and judge
26 Reinholtsen reacted negatively to Remington thereafter, and arguably that was the exact day that
27 said court turned-against Remington and decided to improperly and erroneously end these cases
28 based on defendants frivolous and repetitive collateral estoppel motions.

427
1 Remington was lawfully merely trying to get a basic 8-word summary of Randalls surprise
2 (previously undisclosed) trial testimony and to take his immediate deposition; however Gans
3 abusively, maliciously, and extortionately refused to divulge any part of Randalls planned
4 testimony, which had the effect of improperly invoking surprise at trial with a witnesss testimony
5 which was totally undisclosed even one day before trial. That prejudicial surprise was
6 surprisingly backed-up by the too easy-going, Brisso and Gans-favoring court, which NEVER, ever
7 challenged, questioned or admonished its old law partner Gans, on anything. Remington has
8 asserted that there was plenty for the court to question, as Remington had raised more than 50
9 individual serious ethical or law violations by Gans alone, and Judge Reinholtsen never commented
10 on, admonished Gans or expressed one word of concern about even one of those dozens of corrupt
11 ethical violations.
12 This Randall episode is another example of Gans unethical, and improper use of surprise and
13 his general abuse of Remington in his litigatory behavior. Gans obstructed justice, practiced
14 improper surprise and lack of disclosure regarding everything that he did, generally failed to
15 properly meet and confer and then lied about it afterwards and claimed that he had done so; and in
16 general he abused Pro per Remington in numerous ways for years because he knew that Remington
17 would not be believed by the courts, would have trouble deciding how to combat abusive practices
18 and would overall be ineffective in his attempts to overcome Gans corrupt litigatory tactics. Given
19 the fact that the Humboldt County courts, which were hearing these cases, were rather clearly
20 biased and prejudiced in favor of their former law partners, Gans was substantially correct in his
21 prognostications. But, Gans blatant RICO protective racket extortive activities and intent was what
22 eventually seriously crossed-the-line into the RICO racketeering activity complained about herein.
23 Randall was an old, very insignificant former neighbor who rented a house across the street
24 from Remington for a few years, and before he left became a quasi-enemy of Remingtons who
25 committed acts of timber defacement, theft, and grave ingratitude, for the favors Remington
26 rendered him30. About all Remington now remembers of him from approximately 30 years ago was
27 that he violated a friendly agreement with Remington, wherein after about two years of badgering,
28 30
.The phrase no good deed goes unpunished comes to mind summarizes situation, which apparently is
more of a general problem than just Randalls initially ungrateful behavior, evidently followed-up now
with outright belligerence, revenge and criminality.
428
1 Remington eventually reluctantly gave him permission to enter Remingtons locked gate and
2 property while Remington was away (daily) in Crescent city for many years, in order for Randall to
3 top three alder trees which purportedly blocked part of his ocean view. Instead of staying within our
4 simple and limited agreement, Randall went drastically beyond what had been reluctantly permitted
5 and proceeded to cut-down a large group (stand) of about a dozen of Remingtons Alder trees
6 around 1990. instead of just topping said trees, as he had agreed to do, he took the easier way out
7 and cut them off only 2 feet above ground level which effectively killed them. Simultaneously, he
8 trampled and otherwise removed all surrounding brush and even weeds, which in combination with
9 the dead trees quickly caused serious erosion on that steep slope and set other related conditions in
10 motion which eventually destabilized that whole hillside, leading to massive slides beginning-in, or
11 at least first discovered in 2013.
12 Gans, deceitfully knowing the entire unpleasant history between Remington and Randall
13 deliberately played upon Remingtons fears and old enmity towards them by threatening to use
14 Randall as follows:
15 1) Gans threatened primary improper and illicit Trial use of Randall as a hostile witness was then
16 inferred to be to accuse Remington of various irrelevant environmental crimes, more than 100 yards
17 from the contaminated dumpsites at issue, based upon the contrived, invented and otherwise
18 material false facts that Remington himself had severely contaminated his own property and in that
19 imaginary and impossible process he had also deliberately contaminated Mathsons property.
20 Testimony of that sort was a lot of fantasy, but in Gans able criminal hands he could very possibly
21 make it believable to a nave jury. However, since we have not been able to depose Randall and he
22 has written no declarations or made any other statements in any of these several related cases, at
23 this time we cannot be absolutely certain of exactly what he was coached to swear to. The only
24 thing certain is that it will be false and substantially or entirely perjury. Now Randall can perjure
25 himself in written federal discovery and then follow that up with a deposition in this case;
26 2) As alluded to above, it is known from Gans pretrial innuendos and fear-inducing subtle threats,
27 that Gans and Randall had corruptly plotted to falsely and hurtfully accuse Remington of serious
28 criminal evidence tampering and specifically of either inadvertently or deliberately spiking both
properties with gasoline, diesel, used motor oil, and perhaps even with the 15 to 20,000 pounds of
429
1 deadly asbestos pipes also. That supposed spiking (by Remington) in any event, caused all the
2 contamination on both properties, and hence Mathson was falsely accused and contaminated
3 nothing; however, just like a Trump false fact or fake news a thorough investigation or
4 simplistic logical and scientific consideration of what Gans is actually alleging here can
5 immediately be reduced to absurdities by any thoughtful person, just based on gravity and
6 common sense principles, such as that: water flows downhill and not uphill, etc.;
7 3) In other words, essentially Gans inferentially intended to use Randall to falsely blame
8 Remington for contaminating both properties, the environment and the entire neighborhood. Gans
9 deceitful plan involving Randall was, and still is, therefore a serious threat to: Subject Remington
10 to emotional hatred and contempt from his neighbors; Destroy his integrity, expertise, and the
11 scientific tests done by his renowned environmental expert consultants; and, similarly to
12 simultaneously destroy his character in the news media and to additionally damage his property, all
13 probably irretrievably and indefensibly;
14 4) Gans corrupt extortive, enterprise protection-racketeering attempt here, was also a threat to
15 expose some unknown, nonexistent and hence secret criminal acts, which Gans refused to reveal to
16 the court in May 2016, wherein Gans deceitfully inferred that Remington supposedly had carried-
17 out of some unknown ( and imaginary) type of criminal or otherwise reprehensible act, with
18 unknown details and in an unknown time frame. Similar to all of the acts and potential testimony
19 above, Gans has no rebutting facts about anything that he is willing to reveal now but is attempting
20 to use surprise and probably possible guilt about anything, to enhance the anxiety and fears that
21 any old litigant would have conducting a jury trial without any assistance. THEREFORE, as
22 explained throughout, EXTORTION by the protection racket conspiracy and the simultaneous
23 generation of false fears intended to force Remington to capitulate and surrender to the Enterprises
24 objectives, are again, the very essence of what these contamination cases have degenerated into;
25 5) Obviously, in the classic, well-developed style of a brilliant and professional extortionist,
26 Gans RELIES very heavily, if not entirely upon the very vagueness of his false innuendos, for his
27 desired impact of producing grave fear in Remington. Those surprising and unknown false facts,
28 which were supposedly really important and thus intended to engender great fear, were to be
promulgated and expressed to Remington and the world for the first time ever by Randall in the
430
1 middle of a trial. In mid-May 2016, Gans vaguely hinted at his fantasy of imagined and nonexistent
2 evil acts by Remington, without being specific when Remington inquired, which evasiveness and
3 mystery only (intentionally) enhanced Remingtons fear, and hence the effectiveness of Gans
4 extortion, all of which here again was carried-out to further the objectives of his corrupt enterprise;
5 6) So again, the purpose of all of this wasTo intentionally cause Remington to become too fearful
6 to try or defend these cases, if in fact Gans got lucky and happened to randomly find something
7 that Remington might have felt guilty about. Gans was hoping that Remington would bend over
8 and admit defeat and surrender all his land to the Mathsons and defendants, including that large
9 and important tract which Mathson had already encroached upon and already criminally occupied
10 (and STILL does in 2017), without paying any rent. Additionally, Gans, Mathson, defendants and
11 all of them, seek to take over and appropriate all of Remingtons additional land south of the
12 Creek, which is also now drastically reduced in value by the cost to remediate, plus the obvious RE
13 market stigma and the very realistic fears of major cleanups being ordered in the future by the
14 presently involved regulatory agencies. That major stigma and enormous future risk of eventually
15 ordered major environmental cleanups by regulatory agencies in this area, so that Remington Creek
16 can be made clean enough to use for local drinking water, will definitely remain after cleanup. The
17 net effect of all of the above is to make Remingtons entire state now unsalable, totally
18 unmarketable according to Remingtons expert Frank Scolari, and therefore almost valueless,
19 except possibly as a rental site for someones single mobile home. Those eventual mathematically
20 determinable stigma damages will need to be recovered in a separate successive action lawsuit in 5-
21 10 years, after a sale of the entire estate, or failure of same.
22 Randall has not yet testified and Judge Reinholtsen surprisingly blocked his deposition, so we
23 do not know exactly what false script Gans has written for him yet. All we definitely know is that a
24 false script has been written, And since it is never just the honest truth about what happened, it will
25 by definition be largely or entirely false, internally illogical and probably scientifically impossible,
26 and will contain mostly, improperly-coached and most likely perjurious mischaracterized
27 prejudicial fantasies and inventions from Gans. Today, we just dont know exactly what those will
28 be yet.

431
1 Therefore, in this overall RICO context and Gans frivolous fraudulent (now settled)
2 DR060669 lawsuit against Remington, Randalls still secret, and expected largely false testimony is
3 a further transparent attempt by Gans to force Remington to give-up his affected million dollar
4 property free, without a trial, and in accordance with the enterprises objectives. That is classic,
5 textbook extortion which has been Gans specialty for several years now.
6 Primary environmental defendants Mathson and RAO, et al, impacted, contaminated and
7 ruined Remingtons and the Burl Trees adjoining land beginning in 1998. That presently occupied
8 valuable business property land, including what is impacted directly below it, is worth more than
9 $120,000 for said impacted and appropriated land alone, which potentially could be split-off as a
10 usable and buildable parcel, with a septic system in the region of present Tank C, or were
11 Remingtons burl storage piles exist today.
12 Additionally, defendants have defaulted on their $12,000 per year rental value obligation, and
13 with back-rent for 18-years now due and demanded, defendants back rental obligation alone totals
14 over $216,000, and rising $1000 per month. That rather large back rental sum due and now payable
15 is another major dollar sum which the RICO enterprises objective is to AVOID, forever.
16 Because Remingtons entire very valuable development and estate is now unmarketable,
17 Remingtons and the Burl Trees present total land and building depreciation damages alone are in
18 the half a million dollar range alone, PLUS said above $216,000 back rent due, all of which is why
19 CLEAN-UP of defendants hazardous wastes are now immediately required, while all parties live31.
20 Gans has strongly inferred on the record in pre-trial March-May Severance hearings,
21 before settling his frivolous offensive case for visual nuisance to appease and bribe the
22 Mathsons, that Randall would falsely swear that Remington contaminated his own property and
23 creek and has also implied that Randall is the one who sold RAO and Mathson the important 6
24 SOLID black plastic flex pipe in 1998, which defendants still maintained to this day is perforated
25 . Clean-up is reasonable under Starrh v. Starrh, Mangini I-III, etc because Remington has many
31
long-expressed special reasons for absolutely implementing a clean-up, when defendants

26 provide the funding, plus an expenditure of $160-200,000 for soils AND water remediation will
27 restore the overall fancy estate, residence, gardens and county park back to its pristine value of
about $750,000, as is. Almost completed, when the gardens and structure and driveways are
28 completed and finished up to the large French gothic, cathedral ornamented structure itself, for
about a final $100,000, the overall project could be sold for SEVERAL million dollars, i.e.
potentially $3-6 million, on the international high-end market for unique estates.
432
1 although inspection of it in the ground proves that it is solid. Inferentially, Gans script calls for
2 Randall to falsely swear and assert that he sold some 6 perforated pipe to RAO in 1998, and that
3 therefore what is now in the ground on Mathsons property is that same exact pipe. All of that is
4 totally absurd, entirely unprovable and strictly false logic. Not only can none of goes speculative
5 facts be proven, but Remington will in fact prove the opposite and that all of Randalls imagined
6 and anticipated testimony is false, and intentionally perjurious at that.
7 Of course, Randall does not specifically recall, amongst the hundreds of millions of dollars
8 of Piersons sales since then, selling two rolls of six-inch perforated pipe to anybody in 1998, and if
9 he did, he has no idea where it went. What is absolutely known is that since he did not personally
10 install any of his pipe on Mathsons property in the exact location which is at issue, what he may or
11 may not have sold to someone who couldve used it on any of a dozen projects, is completely
12 meaningless. Here, in the case of RAO, a major contractor and user of such pipes they probably
13 bought many hundred foot rolls of six-inch pipe in those years both solid and perforated. For
14 example, Remington and his contractors have purchased and used more than 20 rolls of similar
15 black perforated and corrugated pipe, mostly 4-6 inches in diameter. Hence, theres nothing that
16 Randall could say on the topic of six-inch black pipe that would make any sense at all, because
17 simple inspection of the ground here today proves that that particular buried pipe at issue
18 significantly, is absolutely 100% solid and not perforated. Therefore, what some merchant like
19 Randall may or may not have sold to RAO or Mathson in 1998 is entirely irrelevant as evidence in
20 these cases.
21 Put in different words, since the 6 pipe in question buried on Mathsons land has absolutely
22 been proven to be solid, therefore what perforated pipe Piersons Hardware may have sold to
23 Mathson or RAO at any time at all is meaningless, because obviously someone also sold them solid
24 6 inch pipe. Obviously Piersons, ALSO sold some solid 6 pipe in that era, which they did not yet
25 LOOK FOR in their sales records, probably, but if not, Hensells Materials had it, and sold it much
26 CHEAPER than Piersons in 1998, in any case. For example, we purchased all of our 2000 or more
27 feet of perforated black drainpipe from Hensell's and not Pearsons. Randalls deposition demand
28 will be reasserted imminently, but now in this federal case where it will have more bite now and a

433
1 substantial meaning, as will detailed Discovery demands about ALL related 6 Piersons black
2 corrugated pipe sales from 1995-2000.
3 Gans additional frauds here are of the federal MAIL and wire (phone & internet) variety
4 because all of his fraudulent, illicit cover-up requests to Randall, and Gans known elicit ordering
5 him to duck Remington and not talk to him, in late May, in order to continue the enterprises
6 classic extortion and keep Remingtons fear rampant. Much of Gans coached false Randall
7 testimony regarding opposition to Remingtons severance motion in March-May 2016, was also
8 mailed, discussed over the phone, as well as in person, and ALL were discussions and devices
9 planned by Gans for Randall to implement in his testimony, and therefore essentially by definition
10 they were mostly intentionally false. Extensive additional discovery is needed regarding Randall,
11 his testimony and his criminal acts committed at 832 Westgate Dr. during the late 1980s or early
12 1990s. Obviously, Gans discussed the enterprises CHIEF and overriding objective of crushing
13 Remington without costs, adverse ramifications, or too onerous prison time for anybody; and, one
14 of their important other major objectives (above) was also to make money for all, and that
15 especially includes Randall who is believed to have a fairly large family, at least several daughters
16 and he certainly was very poor when he lived in the rental across the street from Remington, as
17 described above.
18 36. Gans enterprise has committed MANY more instances of mail and wire fraud, ( 1341 &
19 1343) that are well-known TODAY, plus many others that are inferred, and that will be
20 proven with future discovery, assuming that the Court allows this RICO case to move forward
21 naturally. About 20% of those mail frauds known now are provided below, and the remaining 80%
22 inferred or believed to exist after we locate, analyze and closely scrutinize the tens of thousands of
23 pages in these files, will be supplied in the future as needed, although the discovery starting
24 immediately, should produce much deeper and greater mail and wire frauds than what we presently
25 possess.
26 In other words, many more specific mail and wire frauds are known to exist between
27 defendants and Remington; and among ALL 35-40+ defendants themselves, which harmed
28
Remington, and his business the Burl Tree simultaneously.
434
1 Copies of all Gans overtly executed racketeering and malicious schemes will be further
2 examined during extensive Discovery herein, and at the Dismissal stages, as needed, especially
3 those that were communicated in writing among the upper-echelon racketeering leaders, including:
4 Gans, Kluck, Lawrence, Brisso, Ferriman, Randall, Plotz, Nelson, the RAO defendants and Both
5 Mathsons32.
6 Lower level communications to the soldiers and lowest technical and clerical field
7 operatives occurred mostly by phone and in person for Gans extensive COACHING sessions, as
8 to Ferriman, the Kishpaughs, Costa, Evans, John and Joy Mathson, Pulley, Randall, Nelson, Conn,
9 Skillings, Olson, Gwinn, Hillyard, Schwartz, the file room moles, etc. One issue soon will be
10 however: How much did Randall, Hillyard, Schwartz, Olson and/or Ferriman or Nelson tell their
11 secretaries or other close confidants? MANY of those here named, and as yet UNNAMED, knew a
12 lot and/or should have known this was all an illicit, unethical and also a criminal enterprise, but
13 what was actually and honestly known by each individual RICO defendant, as well as what
14 intentional criminal acts were done with conscious awareness of the damages logically being done
15 to Remington, and when each of these specific acts occurred, will be a slow developing Discovery
16 investigation; however, Remington is now quite patient, at his advancing age, with little else that is
17 anymore important to do, until this is completely resolved. Justice takes time here, obviously and
18 better SLOW justice than fast racketeering INJUSTICE as Gans still plans and schemes. How many
19 of his fellow enterprise members and/or fools go to the gallows, or big house with him is NOT
20 of any concern to him obviously, after observing and understanding him for 10 long years now.
21 Gans has one and only one obvious concern.
22 18 USC 1341 mail fraud is a rather simple statute and provides, as paraphrased to be relevant
23 here: Whoever, having devised or intending to devise any scheme or artifice to defraud or for
24 obtaining money or property by means of false or fraudulent pretenses, representations or
25
32
Obviously, as in any Racketeering case, there will now be a panicky race to locate and
26 DESTROY all criminally incriminating documents, which is where the lower level employees
27 and criminal authorities can play obvious roles. WHY should Julie McBride, Marcie Conn,
Kishpaugh, Joy Mathson or Plotz do HARD TIME for being seduced by Gans charisma,
28 confidence and charm? Thats what THEY can be thinking about this easter season, and far
beyond, where they now should carefully consider how much DEEPER they want to bury
themselves into Gans holes, or whether they want OUT, in the first wave of immunity grants.
435
1 promises. for the purpose of executing such scheme or artifice or tempting so to do, places in any
2 post office or authorized depository for mail any matter or thing to be delivered by the Postal
3 Service (i.e. mails anything related to said fraudulent scheme or artifice)...shall be fined
4 under this title or imprisoned not more than 20 years, or both. WIRE fraud has similar
5 components.
6 Likewise, the elements of mail and wire fraud are deceptively simple, very broad and very, very
7 applicable here:
8 1. intent;
9 2. a scheme or artifice to defraud or the obtaining of property by fraud; and:
10 3. a mail or wire communication, 18 USC 1343.
11 Many documents will shortly be sought by the obvious, investigating authorities plus
12 Remington, on all relevant enterprise business. Illicit Topics, many with federally actionable
13 fraudulent potential, primarily from the attorney leadership and Brain-Trust, including especially:
14 Brisso, in emeritus; operating CEO Gans; potential Co-Godfather wanna-be Kluck, chief all-
15 purpose substitute Kloeppel, secretary McBride and Treas. And vice president of finance,
16 Lawrence; and last but not least, young enthusiastic apprentice, personal assistant and
17 Consigliore Plotz), include, without limitation:
18 Gans final written SOL trial deceitful positions details, in motion, preferably with
19 handwritten notes in the margins, and in MIL form, for the most part. Gans office records, notes,
20 files, personal writings involving these cases and planning sketches, etc will now need to be seized,
21 and then fully indexed and cross-referenced because it can obviously be inferred that such
22 incriminating records had to exist in order to keep the lies, dates, time lines and multiple collusions
23 consistent, a rather impressive achievement; because it is obvious that Gans will purge, burn and
24 destroy all incriminating documents as quickly as he can, they either must be seized quickly by the
25 authorities or reconstructed from witnesses and copies scattered throughout the enterprise, and then
26 analyzed by incriminating omissions, in effect; the SOL trial transcript will be procured to
27 compare all that to; ALL financial transactions and essentially all the scores of BIG CHECKS sent
28 by Allied and endorsed by the Mitchell firm will be required promptly, including all cash and/or
check payments from Allied, for any and ALL Mitchell expenses claimed, with or without
436
1 dispute, explanation or audit, in order that we can reconstruct the entire corrupt sequences, dates
2 and driving financial forces which sustained the enterprise; Any explanations, notes,
3 rationalizations or internal memos regarding Gans false federal judges quotes in his CE SJ
4 documents; ANYTHING (at all) related to and/or explaining Reinholtsens shocking 180-degree
5 REVERSAL on federal collateral estoppel, after his STRONG 5-year clearly articulated
6 OPPOSITE position. WHAT could cause such a radical reversing of position amidst intense pre-
7 trial proceedings when the judge is under serious threat of criminal indictment himself?; Fraudulent
8 writings exist pertaining to trial schedule, dates, times, durations, witnesses, witness vacations and
9 absences, and witness trial topics, etc.; Malicious prosecution concepts, frauds and how Gans and
10 PLOTZ plotted to set-up Remington to keep that extortive deception, and FEAR in Remington
11 alive; What wrings exist between Plotz, Brisso, Gans, et al as to how to deliberately execute
12 their continuous deliberate fraudulent scheme of misinterpreting most California contamination law
13 Supreme Court case teachings, which was somehow broadcast and dispersed to Gans experts and
14 especially to Judge Reinholtsen and the other already believers of and in Gans. Remington
15 assumes that Gans deliberate long-term deceptions of all judges in these cases, exists somewhere
16 as written plans in Gans offices and likely on his computer hard drives, and it will be important for
17 the authorities to timely SEIZE same. Criminal conspiracy notes and plans are NOT work
18 product OR privileged. However, knowing Gans criminal nature all too well, it is most likely that
19 Gans and his inter-leadership core will effectively destroy all incriminating writings and may not
20 have kept a lot of written notes in their files because they had a clear intellectual grasp of what they
21 were doing and therefore transmitted their worst criminal intentions orally. Therefore, since torture
22 appears to still be unlawful at this time, we will have to rely on the next best thing of lengthy astute
23 very carefully planned-out and cleverly executed sequential depositions of the principals, plus one
24 or more whistleblowers coming forward to avoid prison, as anticipated above.
25 By the time of federal trial or the next state trial, Remington expects to have at least 75
26 MORE, better wire and mail fraud examples to present, with at least 30 or more, expected to be
27 irrefutable. Formal discovery is needed however as indicated, after Remingtons appropriate
28 document files from 2012-2016 are given seriously needed chronological record reorganization
this winter, especially all Remingtons disorganized summer 2016 files and documents.
437
1 Remington does not NEED any more mail or wire fraud examples to prove he is being
2 assaulted by a RICO enterprise, and does NOT depend herein on mail and wire fraud predicate acts
3 to prove said RICO conspiracy, and in any case has a lot more than just two of them today to
4 augment the at least 10-20 other SERIOUS racketeering crimes in the other areas cited. Gans
5 enterprise relies mostly on extortion, as explained plus dozens of other related corrupt activities
6 described herein. Similarly, because Remingtons contamination case is irrefutable and stands
7 alone, sooner or later all of this will work out and eventually it may be only Remingtons time and
8 Allieds money that will have been lost here.
9 Gans schemes to defraud were advanced and concealed in the thousands of pages of these
10 letters and specifically cited emails below. Although the fraudulent statements and perjurious plans
11 and results themselves need not be fully transmitted through the mails to violate 1341 and/or
12 email wires to violate 1343, with Gans and Plotz, that WAS done in various specific cases, if
13 possibly only in maybe 5-10% of their estimated 30,000 total filed and/or served litigation pages,
14 over 9 years, and involving 4 lawsuits33.
15 For the purposes of this document, no important purpose is served by distinguishing between
16 US mailings and internet emailings of Gans fraudulent schemes and artifices. In many cases an
17 email was sent initially for various tactical reasons, often fraudulent in themselves, but then
18 ordinarily followed-up with a US mailing, however, there was never any guarantee of a US mail
19 follow-up.
20 Specific 18 USC 1341 & 1343 mail and wire frauds, for defendants to contest NOW, with
21 more added at least weekly, include as begun gathering together in November 2016, without
22 limitation:
23 A. February 26, 2015 email from Plotz to Remington, wherein they violated an email
24 stipulation, intimidated Remington and attempted to take advantage of Remingtons near fatal
25 33
18 USC 1341 and 1343 are extremely broad and criminalize every scheme to defraud that
uses mails at any incidental stage of the fraud. The Supreme Court has held that said statutes
26 encompass everything designed to defraud, by way of representations as to past, present or future
27 promises. Lower courts have progressively expanded this ruling finding that said acts emphasize
and insist on accepted moral standards and conduct and condemns unethical conduct which fails
28 to match the accepted standards of moral uprightness, fundamental honesty, fair play and rightful
dealing in the ordinary and general business life of members of society, Blachely v. US, 380 F 2d
665, (5th Cir 1967)
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1 illness and very weakenedPhysical state. The topic Remington wanted to orally discuss and which
2 he eventually DID discuss, after being driven to the courthouse and getting to Courtroom 8 on a
3 walker, related to Gans serious federal violations of several 1963 federal laws, including the
4 aforementioned egregious misquoting a federal judges order and Gans attempted extortion of
5 Remington and the Burl Tree in order to STEAL (burglarize) Remingtons land and confuse and
6 deceive Judge Reinholtsen and obstruct justice in so doing.
7 Remingtons time in conducting all of this attorney and/or paralegal level work is worth
8 something, especially when merely defending himself from a corrupt RICO enterprise sworn to
9 destroy him. If Remingtons allowed rate of pay is $50/hour x 20 hours thats $1000. Each frivolous
10 litigatory act by Gans cost the Burl Tree at least that in lost products manufactured and NOT sold,
11 with net profits being about 90% of sales in many cases, which means that lost sales are often
12 almost equivalent to lost profits and damages. More detailed analysis of these damage and injury
13 concepts can be found in the last sections of this complaint.
14 The Enterprises fundamental purpose in conducting the above mail and wire fraud
15 exchanges, like most, if not all of the rest of the examples below, was merely to defraud, intimidate,
16 extort money and personal and real property from Remington. That is, US Mail and Internet were
17 used here to execute the enterprises intentional fraudulent objectives to obtain both money and
18 business property from Remington. If any of the defendants are found guilty of executing such a
19 scheme or artifice, or attempting to do so, they shall be fined and imprisoned up to 20 years,
20 according to the statutes.
21 B. The July 16, 2015 email from Plotz to Remington, while he was in OREGON, with
22 defendants fraudulent, incomplete, non-responsive and frivolous Declarations and 2015
23 Remingtons summary judgment responses, intended to deceive and which damaged Remington by
24 having to prematurely abort a $3000 Oregon trip to return early. This incident exemplifies the
25 actual interstate commerce and out-of-state character of many of these damages.
26 US Mail and the Internet were used here to execute the enterprises intentional fraudulent
27 overall objectives of obtaining both money and business property from Remington and his business.
28 If any of the defendants are found guilty of executing such a scheme or artifice, or attempting
to do so, they shall be fined and imprisoned up to 20 years, according to the statutes cited above.
439
1 Aborting his Oregon trip due to the confusion engendered by Plotzs errors and fraud also cost
2 Remington another $5-10,000 of estimated profits, as Lorn Sandberg, of Burl on-Line lives
3 only 3 miles from Remingtons route through Albany, Oregon and Remington was unable to show
4 him his lace redwood burl samples, they had discussed on the phone in 2013, and 30 other times in
5 person, since 1980. Remington has more than $200,000 of redwood lace burl which Sandberg could
6 use and sell from his web site, some portion of that amount was lost at the time and will now be lost
7 forever.
8 C. GANS and Plotzs August 12, 2015 email, further extorting Remington over expert
9 Foget, wherein GANS and his apprentice Plotz began a 6-week obstruction, extortion, common
10 every day harassment and witness tampering process which had the DEADLY serious well-
11 executed unethical purpose of intimidating Remington, to FORCE the technical LOSS of ALL of
12 his environmental experts. Well skip the complicated details herein, covering about 30-pages of
13 previously filed documents, but Gans and Plotzs illegitimate attempt to trick, extort and defraud
14 Remington by forcing the deposition of crucial de-designated primary expert Mike Foget, to
15 statutorily and technically insure that Remingtons REAL expert, Dr. McEdwards, could NOT be
16 deposed, which was unforgivable.
17 Remington happily figured-out the fraud this time and potentially case-ending lethally
18 technical TRAP by doing a few days research, but does that make it RIGHT by the enterprise, and
19 any less of a subordinate but significant unethical and corrupt act by the enterprise? As above, even
20 Hitler and the Godfather sometimes obeyed the speed limit and a few societal norms, or encouraged
21 someone to occasionally do the right thing on their OWN volition, and not only because they were
22 extorted verbally or in writing, or because they were terrified and willing to submit to anything,
23 after their horse or son were murdered.
24 Gans serious lack of integrity and ethics in general began in 2008, but gradually
25 developed into and became corrupt RICO protection racket acts sometime after 2012.
26 Is Gans and his enterprise innocent of wrong-doing? Obviously NOT. The majority of what
27 they do is wrong, unethical and usually as blatantly unethical as an attorney can be without getting
28 summarily disbarred by a judge. Here, the Humboldt County judges, to date have been too busy,
turned-off by Remingtons accusations and pro per status, and/or perhaps bribed or otherwise
440
1 inferentially improperly influenced. The only exception so far, and obviously objective and fair
2 judge in these cases to date was Judge Marilyn Miles in 2008-10, who saw through the Mitchell
3 firms overall corruption back then, if not before that. Therefore, when she was again called upon in
4 2014 to hear a crucial summary judgment motion, as soon as Gans learned that she was going to
5 become involved again in these cases, he immediately disqualified her. Unfortunately, for an
6 attorney to be disbarred or sanctioned on a HATED pro pers say-so or complaint is a SUPER-
7 RARE occurrence and Remington has never seen a California or Federal case where that occurred,
8 in 5,000 read cases, plus 5000 others skimmed.
9 The point? Gans is a very disingenuous, dishonest and very UNETHICAL practitioner, as
10 perhaps argumentatively but honestly alleged above, and significantly also proven with several
11 hundred specific examples. As explained, Gans is NOT corrupt all the time in his every waking
12 act, with every letter and filing, and presumably not with every client, or opponent. But HERE,
13 about half of his writings are more unethical and false than NOT, by a statistical or preponderance
14 of the evidence standard, depending on the specific criteria used, whether word count or general
15 impact of all the points made or issues raised, etc.
16 MORE important than that, i.e. whether Gans is overall 50% unethical and intentionally
17 wrong, misleading, deceptive, ETC OR only 20% dishonest, is the CRIMINALITY element. This
18 RICO case is about a racketeering enterprise led by Gans and supported by many other nice
19 conventionally-dressed, ordinary acting business people around Eureka.
20 WHAT PERCENTAGE OF GANS UNETHICAL ADVOCACY ACTS CROSS THE LINE
21 INTO CRIMINALITY AND BECOME FEDERAL PREDICATE ACTS? That question interests
22 Remington and hopefully this court. Remingtons quite astute long-time psychological, legal,
23 competency and ethical study of Gans, would today postulate that something like 40% of all Gans
24 current work involving Remington in any regard is illicit and/or so UNETHICAL as to warrant
25 suspension, and/or outright DISBARRED by the California Bar Association. Possibly only 20% of
26 his entire body of work opposing Remington is disbarment-grade, because the corruption has only
27 become serious at the crisis and imprisonment level, only rather recently, but now clearly appears to
28 be in an exponentially increasing mode. That will be good if Gans continues with that criminality in
this federal RICO case, where severe penalties for all of his state perjurys and obstacles of all kinds
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1 abound, as described. What Gans does with other clients is unknown now, but not for much longer,
2 as that has also become RELEVANT here.
3 The REAL ISSUE NOW IS: What percentage of Gans enterprise work crosses the NEXT
4 LINE, WAY-DOWN the hill, into criminality and federal predicate acts? Again, as above, obviously
5 not all his work and in fact not very many of his activities warrant sending him to prison. Maybe
6 only one in 50 or one in 100 actions and criminally executed thoughts he has in the Remington
7 case. BUT, two over 10 years is enough and 35 are way TOO many. Despite Opposing a detested
8 pro per, at some point if a licensed California lawyer provably commits 10 murders, 2 bank
9 robberies and 20 strong-arm extortions, the burden of proof eventually switches from the pro per to
10 the lawyer to GO UNDER OATH AND SWEAR THAT HE IS TELLING THE TRUTH AND TO
11 SIMILARLY SWEAR THAT REMINGTON IS THE LIAR. Weve been down this road
12 repeatedly. Remington has declared and SWORN to about 5000 pages of facts in these cases and
13 Gans, Mathson and ALL of them, MUCH, much less. Not counting depositions, Remington swears
14 to facts at least 100 to 1 more than Mathson and about 1000 to 1 more than Gans swears to actual
15 facts, as opposed to introducing a few uncontested documents in a Judicial Notice volume.
16 Does that PROVE anything? Perhaps not, BUT Gans is going to need to put some sworn
17 facts on the record here now to defend himself and to refute the existence of this enterprise.
18 However, as this court will eventually learn, Gans not only will refuse to do it but he cannot do it.
19 As soon as this court forces him to swear to anything alleged here, these cases will be instantly
20 over because he will have to abandon his crooked defenses.
21 As alluded to above in a different context, Judge Miles in 2009 let Gans get away without a
22 substantive declaration on a crucial integrity issue and then publicly in open court second-
23 guessed herself on that, and began thinking-out-loud that maybe she should require such a
24 declaration, but when the subjects changed, 5 minutes later she forgot to come back to that, and
25 very unfortunately, so did Remington. Eventually after 4-5 oral hearings and about a dozen
26 motion exchanges, she eventually reduced the Mitchell attorney fee requests by about 80% as
27 above, but had she demanded an attorney declaration from Gans THEN and there she was
28 contemplating, which would have had to have been perjured, maybe these cases would have been
over THEN, 8 years ago, and Gans might be just getting-out of jail about now.
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1 In other words, Gans commits SERIOUS Federal predicate acts every year, not 100, but maybe
2 7, and in 2016, maybe 10. TEN in a year is TOO MANY even with a hated pro per complaining
3 about it, so here we are in Federal Court, still trying to find a serious, old-time, no-nonsense law-
4 and-order judge that will not tolerate Gans unethical and criminal behavior. Hes not just a menace
5 and nemesis to Remington, but obviously to the entire legally involved community in Eureka. Hes
6 very skilled, unassuming, disarming and demonic, as specifically involved the organized,
7 SMOOTH direct examination of his perjuring witnesses, among the other racketeering leadership
8 issues above.
9 THIS COURT does not have to take Remingtons word for anything here. The above wished-
10 for process would be real simple: During the first oral hearing in San Francisco, put all parties and
11 attorneys under oath and require a full discussion of some of these issues and watch Gans squirm.
12 Remington on the other hand is willing to put all of his oral remarks under oath and also all of his
13 written remarks, and Is the standard matter of course Remington frequently swears to lengthy
14 documents, which to an attorney would be an ordinary shifty memorandum of points and
15 authorities, containing numerous half-truths, deceptive case citations or worse. Why should Gans
16 not be held to that same standard?
17 Again here, US Mail, the telephone and the Internet were usedBy these RICO defendants to
18 execute the enterprises intentional fraudulent overall objectives of obtaining both money and
19 business property from Remington and his business, by means of a deceitfully and disingenuously
20 Scheme of using a non-deposition of a De-Designated expert, Foget, to eventually bar any and all
21 Remingtons environmental experts in this case. If any of the defendants are found guilty of
22 executing such a corrupt, fraudulent and unethical scheme or artifice, or attempting to do so, they
23 shall, or in a close case, may be fined and imprisoned up to 20 years, according to the statutes
24 cited above, for the specific acts also explained with sufficient particularity above and also below.
25 D. Gans August 25, 2015 unethical advocacy email advancing the above-described and
26 complained of Foget deposition scam, and initiating the attempted trickery regarding all of
27 Remingtons environmental experts: Johnson, Esko, Foget, Hoyos, McEdwards, etc, too complex
28 and peripheral to explain herein (but see C. above, for additional comments and details). In any
case, all details of a 10-year long ongoing complex and contentious litigation need not become
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1 immediately clear to this court, however be certain that defendants, Gans and Plotz in particular,
2 KNOW all too well what the charges against them are an on this issue they will be based upon the
3 above. Is it a Federal crime to screw-over and attempt to defraud a detestable pro per and get him
4 kicked-out of court in any unjust, technically unethical manner possible? Probably not, certainly
5 not in THIS state-based legal system where attorneys can do no wrong, are judged by their peers
6 and former long time law partners or associates, unless they are screwing another attorney, or large
7 monetary embezzlements are involved, etc.
8 BUT, cumulatively, these kinds of minor unscrupulous, amoral, underhanded, corrupt and
9 disingenuous, unprincipled acts, if done to your old crippled mother and not to an obnoxious pro
10 per pretending to be a lawyer, would be somewhat FROWNED upon, if not barred and
11 complained about. If Gans did these things to a judges mother then thered be a PROBLEM and at
12 some point. In any case, Gans has arguably long since crossed all reasonable ethical lines HERE,
13 which is just another way of saying he is conducting a criminal enterprise, and therefore there
14 should be ACTION here now from this court, repercussions and said attorney should have to
15 ANSWER to criminal charges, including RICO charges, now, as repetitively alleged herein.
16 In that regard, it appears likely that in 2017 Remington will also amend his state complaint
17 to add these RICO charges there, as well as reasonably amend his complaint for the next
18 contamination trial, which amendment was improperly and erroneously (under Mangini II) barred
19 during the August 2016 SOL trial but now all that must be put more clearly on the record as to
20 exactly what was barred and exactly why, so that a clearer more streamlined appeal can be made.
21 E. October 5, 2015 email from Remington discussing the deceptions STILL going on
22 regarding pre-trial expert depositions. There are 10 other emails and letters, including the two
23 above at C-D, plus phone calls related to Gans unethical and probably corrupt attempt to eliminate
24 all of Remingtons experts by technical and largely improper means. Those ranged from
25 intentionally escalated scheduling conflicts (between Gans and Remington, deliberately used
26 against him for the past 8 years); to confusing deposition locations (to upset and prejudice
27 important Remington expert Maje Hoyos), and spoiled site evidence (for Dr. McEdwards). Also,
28 Gans employed trick questions (for all Remingtons experts) which were not intended to determine
any truthful opinions on any topics, but were intended to limit Dr. McEdwards and Maje Hoyos
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1 testimonies to the few limited questions on the few limited subjects asked by Gans, when neither
2 fully understood ALL they were going to be asked to testify to on direct, at the time of their hurried
3 depositions. Remington contemporaneously clarified all of that fully on the record, however when
4 Gans recites the record he ignores Remingtons proper supplements and clarifications thereof. That
5 was especially true where Judge Reinholtsen then restricted Hoyos testimony by at least 98%, and
6 to inexplicably testifying ONLY about conditions on another property (uninvolved in this lawsuit),
7 and Dr. McEdwards was restrictively focused to ALL that Aveggio had testified to, no more and NO
8 LESS. In 2015, Judge Reinholtsen very prejudicially and inexplicably denied Remingtons motion
9 to allow his new expert to do some independent testing, and prejudicially restricted Dr. McEdwards
10 to using and relying only upon John Aveggios SHNs 2011 testing. Then during pretrial hearings,
11 Gans attempted to bar all of SHNs testing from the trials, which Dr. McEdwards required in order
12 to render any expert opinions about anything, and said Judge Reinholtsen appeared to be probably
13 going along with that also, but never made a final decision there. This is just another example of
14 how the state case now appears to be so hopelessly bungled, and driven-now by judicial errors, that
15 an appeal will shortly be imminent there, unless this Court takes over the whole matter and the state
16 proceedings are stayed accordingly.
17 The courts error explained in the above paragraph can be summarized: Judge
18 Reinholtsen allowed new expert Dr. McEdwards into Remingtons case, but restricted his testimony
19 to the use of SHNs tests and prejudicially forbid him from doing any of his own additional tests. A
20 few months later, said Judge appeared to be ready to bar all of SHNs work also, which meant that
21 Remington soul environmental expert Dr. McEdwards could then base is trial testimony on
22 absolutely nothing! Does that make sense, or is it just?
23 F. October 6, 2015, more ELECTRONIC WIRE violations, emails, related to Gans
24 frequent BAD FAITH failures to meet and confer over 8 years, which here are still tied to the
25 unsavory expert deposition scheduling above. As previously explained, Gans was still desperately
26 and unethically trying to coerce and/or extort the deposition of Foget, throughout fall 2015, in order
27 to FORCE Remington to technically lose his state case case because he had NO environmental
28 EXPERT. That corrupt action by Gans occurred with Foget, who had been already officially be

445
1 designated as a Remington expert, even after Foget had already been unfortunately barred from
2 Remingtons case by Nelson, which was caused by Gans racketeering influence on Nelson of SHN.
3 If Gans had still managed to depose Foget as he valiantly tried to do for three months, then
4 that wouldve been Remingtons only possible expert, because no OTHER expert would then be
5 deposable as a Remington expert under the controlling CCP deposition statutes. That trap was set
6 for Remington and Gans tried to push him into it for three consecutive months, even though Gans
7 knew that Remington had designated Dr. McEdwards as his environmental trial consultant.
8 Nevertheless, Gans pursued this criminal trickery, as explained trying valiantly to depose ex-expert
9 Foget, and not Dr. McEdwards, so that the result would be that McEdwards could not get into the
10 case, and since Foget had already been withdrawn, the net result as intended by Gans would be that
11 Remington would have no expert and would have to default his case immediately and before a trial.
12 If Gans had been able to execute that treacherous RICO plan, then he and Mathson could
13 WIN by default, similar to their technical and not on the merits federal summary judgment in
14 2011-14, and also meet all of their RICO objectives and get Remingtons land for good with one
15 final fraudulent act.
16 As Remington has attempted to explain here in, Gans does not care HOW he wins, as he is
17 rather clearly a psychopath, in Remingtons humble, psychologically sophisticated estimation.
18 Remingtons wife has very extensive 50+ year top professional credentials in the area of
19 psychological counseling, social work and psychiatric and personality disorder diagnosis, and she
20 essentially concurs with that statement, although she would have many additional diagnostic buzz-
21 words to say about it. Gans must win by ruthless suborning of trial witness perjury, federal witness
22 tampering, obstruction of justice, spoliation of evidence and extortion crimes, murder, torture or
23 whatever it takes, but WIN is what hes sworn to do at any cost, and Remington is now paying those
24 financial, emotional and declining health, very high costs.
25 G. October 13, 2015 letter and email from Plotz, wherein the Foget saga continued, as above.
26 Here they improperly and unjustly demanded from the court that it bar the use of Foget to even read
27 Aveggios deposition or authenticate his signature, all still necessary for Foget to do, but only by
28 court order now, as stipulations are impossible on everything. The court may not have issued a
final ruling on this important state trial contamination issue, but previously was leaning towards
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1 granting any wish that Gans made on any and every subject. Additionally, now we have the added
2 complication that Nelson of SHN, who is Fogets direct boss and superior, is alleged to be an
3 enterprise member here under Gans influence and control and therefore Nelson may-well block
4 Foget from attending trial as a Remington witness even when Foget is subpoenaed.
5 H. February 8, 2016 email to Julie McBride and Gans about various Dr. McEdwards phone
6 calls and emails both ways as to his scheduling at an inappropriate time for Remington and not
7 allowing Remington time to show Dr. McEdwards the polluted property which was Gans overall
8 intention, which was discussed the next day on the phone, at I. These incidents and improper
9 mailings and demands are clearly Not ALL federal crimes, but are merely provided as more
10 examples of Gans making life and litigation as impossible as possibleFor plaintiff, which has
11 continued here for at least 9 years, and which has now embarked almost completely into the
12 Twilight Zone of mostly criminality.
13 US Mail, the telephone and the Internet were used here to execute the RICO enterprises
14 intentional fraudulent overall objectives of obtaining both money and business property from
15 Remington and his business, by means of a deceitfully and disingenuously scheme of attempting to
16 schedule experts at improper and/or impossible hours or days, in order to make a record of
17 Remingtons unreasonableness and then attempt to eventually bar any and all of Remingtons
18 environmental experts in this case, entirely, here Dr. McEdwards and Hoyos. If any of the
19 defendants are found guilty of executing such a corrupt, fraudulent and unethical scheme or artifice,
20 or attempting to do so, under 1341 & 1343, they shall, or in a close case, may be fined and
21 imprisoned up to 20 years
22 I. Serious 1951 Phone extortion by Gans, and associated ( telephone) wire fraud, 1343.
23 As discussed separately above under Gans extortion, Remington called Gans on the telephone
24 on February 9, 2016 at about 4 PM for at least a 25-minute discussion, to complain about Gans
25 abusive deposition scheduling, and to negotiate a different time for McEdwards deposition, which
26 Gans sadistically and calculatingly refused to change, because he knew it was inflicting pain,
27 irritation and injury to Remington.
28 When Remington did call him however, Gans did use that RARE phone opportunity to
bend Remingtons ear at length, to make one of his impassioned self-serving BS speeches and to
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1 TELL Remington a lot of other pertinent, but unwanted, intimidating and anxiety-creating
2 information about his supposedly peaceful objectives and what amounted to a fraudulent and false
3 statement of his overall purposes, which as we have explained is very simply, no less than to
4 extort most if not all of the Burl Trees property, at no cost to defendants. During that conversation,
5 Gans attempted to use a variety of his best devices and sales closes, ETC, such as attempting
6 to use a badly executed sympathy close (which is well-known to be among the most ineffective
7 closes a salesman can use), about the nice, poor Mathsons sad and unstable mental state in an
8 abortive and transparent attempt to unsuccessfully convince Remington to stop this lawsuit and
9 NOT go to trial. Generally, Remington felt Gans tried to make it easier to end Remingtons
10 litigation by making Remington an offer he could not refuse, (involving an intimidating threat
11 inspiring FEAR) which involved NO money, and 100% capitulation by Remington to avoid
12 appeals, costs, malicious prosecution, fraud charges (against Remington!) and the fantastic,
13 once-in-a-lifetime opportunity to avoid all responsibility for ALL Mathsons hundreds of
14 thousands of dollars of attorney fees, for 10 years in effect.
15 That was Gans stated plan at the time, which was in effect, to charge Remington with
16 numerous crimes, all with expensive sanctions and financial penalties all intended to ruin
17 Remington financially and at this time (2-9-16) to cause fear in him so that he would end the
18 litigations and not go forward with the imminent trials.
19 That was then and THAT still is Gans wise strategy now: Eliminate any possibility of
20 hope in Remingtons mind of a positive, reasonable and just settlement, involving paying to
21 Remington his reasonable damages and clean-up costs, such as the roughly $100,000 super-lowball
22 attempted settlement that defendants offered to Remington in 2011 at the state pre-trial settlement
23 conference. Since 2011, and throughout 2016, Gans only focuses on the huge potential financial
24 DOWNSIDE for Remington and the specter of Remington paying Gans, et al, $500,000-1,000,000
25 to just get off this run-away train to hell. Mathson, RAO and Gans are the most-obvious master
26 criminals here, and it was they who damaged Remington in 1998, and afterwards, during which
27 damages have continued for 10 years after 2006 when some of their damage was first discovered.
28 Additionally in this call, Gans said the Mathsons were very upset about my fence being
there and that they would stop at nothing to WIN this and destroy (me) in the process, if it
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1 came to that, which of course Gans claimed he did not want, because he is just doing (his) job.
2 All of that was already absolutely well-known, but it was of some interest to have it articulated so
3 specifically. Why the Mathsons are so angry with Remington when they are the massive
4 polluters, is a peculiar philosophical discussion, involving their grave guilt, for another forum.
5 A few months later it was ALLIED who was the THEY that was mad, not only the
6 Mathsons, and GANS. So, in other words we now know that they are all mad. This lawsuit could
7 be inferred as showing that they are not the only ones. Rather obviously, all three defendants named
8 above, have been very mad and very formidable adversaries for many years and have now formed
9 the RICO enterprise described herein as their last heroic great alliance to finally put Remington
10 away for good.
11 Additionally, Gans reminded Remington of their unlimited resources, no kidding and that
12 Farmers was not helping (Remington) in the contamination suit (at least only about 5% overall).
13 That 25-minute talk cant be reasonably fully summarized here, except that it was taken
14 contemporaneously and still today as an act of attempted extortion, and the attempted could
15 reasonably be deleted because Gans extortion attempt DID actually damage Remington further
16 by causing additional real WORRY, anxiety, waking-up in the middle of the night- type pondering,
17 and considering alternatives, while attempting to sleep; and Gans unpleasant and upsetting tirade
18 and threats also affected Remingtons Burl Tree orders of finished plaques for the US Justice
19 Department, and diminished all other related burl and business work for about a week.
20 J. February 12, 2015, more scheduling problems with Maje Hoyos deposition and Gans
21 very serious attempts to schedule her deposition when Remington was unavailable, again as an
22 example of intimidation and mild extortion, knowing that BOTH Hoyos or McEdwards were
23 crucial to Remingtons case, both had to be deposed essentially whenever Gans demanded it, and
24 either could potentially LOSE Remingtons entire case. Gans also knew Ms. Hoyos was eager to
25 please, was not well-prepared or scripted and coached by Remington, plus she had never had her
26 deposition taken before, so she would have been easy cannon-fodder for Gans deceptive, sly and
27 corrupt style. She would have been also had Remington not been sitting beside her to help her
28 respond to Gans slick prejudicial traps.

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3 Remington and his business, by means of a deceitfully, very determined and disingenuously scheme
4 of attempting to schedule experts at improper and/or impossible hours or days for Remington to
5 attend, in order to make a record of Remingtons unreasonableness, and then attempt to eventually
6 bar any and all of Remingtons environmental experts in this case, entirely, here that being Maje
7 Hoyos. If any of the defendants are found guilty of executing such a corrupt, fraudulent and
8 unethical scheme or artifice, or attempting to do so, under 1341 & 1343, they shall, or may be
9 fined and imprisoned up to 20 years.
10 K. March and April 2016, various Gans to Remington emails and letter pertaining to
11 Hillyards odd, illegal, 5-year too late, extortive testing. Hillyards mysterious and tardy testing,
12 if any was actually even done at all, was in any case, improperly done MORE THAN 5-years
13 beyond the Discovery cutoff and purely intended only to scare and intimidate Remington into
14 giving-up his cases before a contamination trial. This entire odd-episode is truly absurd and
15 outrageous!
Whoever heard of a defendant expert and attorney that illicitly trespassed onto a plaintiffs
16
property to do an illegal discovery investigation without any legitimate maps, photographs,
17
records, witnesses or any verification whatsoever of authenticity, or that it ever occurred at all!
18
This was one of the heights of Gans Enterprises illegitimacy and corrupt activities34. Gans
19
letter with purported benign Hillyard testing results at intentionally UNDISCLOSED, trespassing
20 locations on Remingtons and Mathsons land, INSIDE the fence was intended and received as
21 extortion only. There was no scientific detail or evidentiary merit to Gans communications,
22 because without any testing details and mapped locations, any test results and whose land they were
23 conducted on and where, were obviously, knowingly meaningless. Hillyard, Gans and Mathson
24 34
Gans really needs to answer these allegations and explain exactly what he and Hillyard were
25 doing, when, why and on what authority in trespassing upon Remingtons property and allegedly
and illicitly claiming to do some sort of borings, which somehow Gans now claims supports his
26 case, without providing any details whatsoever that we could respond to. The reason this point is
27 emphasized here is that Gans typically does not respond to and fully ignores any allegation by
Remington which he literally has no answer or explanation for. His rationale in the past has been
28 that if he does not deny or respond to it then it does not exist. Many prior judges have accepted
that axiom and just let Remington make dozens of accusations while Gans smiles superiorly as
though he is above it all, and that Remington is just a crazy Pro Per, or inferences to that effect.
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blatantly TRESPASSED onto Remingtons land, flaunting no trespassing, violators prosecuted
1
signs and said letters were clearly intended to frighten Hoyos, and also Remington and get the two
2
worrying together in to cost Remington more time, money and experts good will and patience.
3
L. May 5, 2016, Plotz to Remington email: Another pissing contest against Remington,
4
ultimately related to the huge preparation done with 100+ comprehensive special jury instructions
5 and about 175 MILs many turned-in EARLY which Plotz and Gans objected to! This email chain
6 essentially started when Plotz was further attempting to intimidate Remington and make it easier
7 for him to give all this up than to keep battling with them. plots objected to the fact that Remington
8 courteously submitted about a hundred pages of MILs one month EARLY! So, they bitched about
9 that. Nothing Remington ever does suits them as its either too early, too late or improperly
10 filed or something else. Those consistent nasty litigation tactics are unpleasant but not against the
law certainly so they have nothing to do with this RICO case. Here, they got a couple hundred
11
pages very early, and hence super-timely and then 20 or 30 pages late, because the court file room
12
didnt stamp something which they should have done, because they didnt like the cover sheet on
13
one of the documents. That was an irrelevant issue in this case, but did block the proper filing and
14
distribution of some documents for several days, as the previous 50 documents had just been
15 handed directly to the judges clerk, in the court and within the court room, and this set of MILs in
16 early May was somehow done out of court, and then was just an aberrant situation, but one which
17 Plotz took it upon himself to object to, as they like to object and make communications between the
18 parties as unpleasant and expensive as possible, even when theres nothing substantive to object
19 about.
20 Many topics and issues were in play in May, 2016: Collusion between Allied, Gans, Kluck
and his insurers, Plotz and/orRemington or Mathson, related to keeping RAO out of the 2016 trials,
21
crushing R at the pre-trial MIL stage, spoiling and eliminating evidence and in a generally
22
coached, perjured and corrupted contamination or later SOL trial when that became a likely
23
scenario. Full details will be provided at the dismissal stage which means actually providing the
24
texts of all material emails and letters, and discussing their significance as required.
25 Damages to Remington included: wasting and paying for his experts expensive time
26 training, reviewing and understanding obscure parts of the cases history, explaining extraneous
27 evidence to multiple expert witnesses, and designing and manufacturing (and color duplicating)
28 unnecessary trial displays at considerable costs, plus his OWN costly time of value to the business.
None of which would have been necessary if Gans was HONEST and ethical, and in any case it
451
would be easier to prosecute the known, accepted facts rather than Gans fictional and perjured
1
facts, written as needed, to reinforce any defensive weakness.
2
Once again, as above, the US Mail and the Internet were used here to execute the RICO
3
enterprises intentional fraudulent overall objectives of obtaining both money and business property
4
from Remington and his business, by means of a deceitfully and disingenuously scheme of
5 attempting to beat down Remington at every opportunity in order to try and make a written record
6 which was always used to embarrass him in the court room.
7 If any of the defendants are found guilty of executing such a provably corrupt, fraudulent and
8 unethical scheme or artifice, or attempting to do so, under 1341 & 1343, they shall, or in a close
9 case, may be fined and imprisoned up to 20 years. In some of these cases or instances, involving
10 mostly just Plotzs acting under Gans direct orders, probably the fine would be sufficient. However,
cumulatively Plotz has also committed plenty of imprisonable offenses as he dutifully enforces
11
Gans criminal orders.
12
M. June 15, 2016, Plotz to Remington email opposing amending complaint, on fraudulent
13
and false grounds at or before the SOL trial. Since the court appeared to Remington to be in
14
Gans and Plotzs pocket, then and thereafter, as per The Godfathers judges, every argument
15
made by Plotz was framed by, almost entirely accepted and acted upon by Judge Reinholtsen after
16
about May 20, 2016.
17
Said email and letter to Remington on June 15, 2016, and other dates, related to Gans April
18
4, 2009 Answer to Remingtons Amended complaint, plus their Opposition to Remingtons motion
19
to amend his complaint citing mostly invalid false statements of facts and the law, such as his
20
permitted alternative statements of permanent vs. continuing nuisance in 2008, wherein Remington
21
can and DID ELECT per Mangini, et al according to the developed and discovered expert facts by
22
trial, etc. Unethical advocacy by the enterprise here, and over the last 10 years, is not a RICO
23
crime, but in support of the REAL crimes herein, these hundreds of similar, analogous,
24
UNETHICAL hyper-aggressive advocacy examples should be factored-in, at the sentencing stage,
25
and also at this preliminary stage where the overall integrity and ruthlessness of Gans normal day-
26
to-day advocacy methods really should be considered as a background to the massive criminality
27
alleged.
28

452
3 Remington and his business, by means of deceitfully and disingenuously schemes of Deliberately
4 and deceitfully misciting and materially misrepresenting the law to the court in the hopes that it
5 would not discover the fraud on its own and NOT do its own independent research, which deceitful
6 defendants plan and intention ordinarily worked perfectly, at least dozens of times. If any of the
9 imprisoned up to 20 years.
10 N. August 22-23, 2016, Gans to Remington Email and US mail letter; This was another
11 intimidating, worrisome thinly-guised written extortion THREAT from Gans regarding the
12 new fence35, threatening DIRE CONSEQUENCES if Remington used his own property and
13 paths on his side of fence going forward or did any damage to Mathsons land (subsidence), when
14 THEY prematurely began excavations in violation of their contract, which have now destabilized
15 the mountain, a few days before the rains, and now will sit quietly through 50+ inches of often
16 HARD eroding 2016-17 RAINS.
17 US Mail, the telephone and the Internet were used here again to execute the RICO enterprises
18 intentional fraudulent overall objectives of extorting both money and business property from
19 Remington and his business, by means of deceitfully and disingenuously schemes of misciting and
20 misrepresenting the law to the court, to Harvey Roberts and to Remington, in this case to attempt to
21 disguise their improper trespassing actions and violation of the purported settlement/bribery
22 agreement. Gans, Mathson and other enterprise members totally jumped-the-gun on the agreement
23 and started excavating, laying-out the fence and setting into motion severe erosion conditions on the
24 4- degree slope between the properties along the Pulley line. Said agreement was not supposed to
25 be put into effect until several years later, and this was a serious violation of it. If any of the
27 35
.This is the fence that was agreed to in the April 2016 extortive $20,000 settlement of DR 080669, which
defendants prematurely began building before the agreed two conditions had been met, and also This fence
28 should have been placed on top of an engineered retaining wall, to avoid its being collapsed during
remediation, which now will be happening, because defendants just ignore Remington and all of his civil
and structural engineering expertise.
453
2 imprisoned up to 20 years.
3 O. Gans-Plotz additional multiple mail frauds through, and including January 27, 2017, but
4 continuing BEYOND. In his letter of January 26, 2017 Gans wrote the following false, LYING and
5 fraudulent statements: 1) Remington did not file a brief on August 19 prior to the 8/2216 deadline,
6 however, Remington absolutely did hand file a 19-page document at the last Department eight
7 hearing, which was supplemented further on the 22nd and again in late January 2017 for the upcoming
8 next hearing. In Judge Reinholtsens first oral sentence at the February 17, 2017 hearing he
9 acknowledged on the transcribed record that Remington had filed a brief as ordered that was in his
10 possession. It was not a proper opposition to Gans post-trial brief as complained, because the court
11 did not justly allow time for that, but nevertheless it was a procedurally proper independent statement
12 as had been solicited by the court; 2) Gans further lied in that letter that email has been the primary
13 method of communication with Remington, because Gans has always refused to recognize it routinely
14 and uses it in less than 5% of his filings. Remington would have preferred using email frequently,
15 however defendants have always avoided and prevented that because it is obviously easier and cheaper
16 and they cannot bill Allied insurance as much for an email as they can for a fancy typed letter; 3) Most
17 importantly, Gans reiterated in writing his essential, crucial and material attempt to deceive the court
18 with his oral request for an entry of judgment of dismissal based on a simple jury verdict in the SOL
19 trial! Whether or when Remington discovered the contamination, as determined in the 2016 SOL trial
20 had little if nothing to do with the ultimate issues which Remington has been suing for now for about
21 10 years. All this was fully briefed for the February 17, 2017 hearing.
22 Most importantly, at that hearing, Gans intentionally committed fraudulent deception of the
23 state court with that request for dismissal in opposition to all pertinent controlling Supreme Court
24 case law. Gans and Plotz above all know that Remington elected continuing nuisance and
25 trespass back in 2011 and after that election whether or not he can recover for his damages for the
26 three years prior to filing that case is a matter for the trier of fact, which here is a jury, and that
27 important issue cannot be ruled upon from the bench, with no data, evidence, expert witnesses
28 provided whatsoever, nor does Judge Reinholtsen have sufficient knowledge or understanding of the
science and law of these cases two rule without any expert testimony or accurate, directly pertinent
454
1 briefing about the law. Said judge also requires substantial briefing because with about 200 other cases
2 to adjudicate and try he has approximately zero time to learn about contamination law for the first time
3 P. Gans June 7, 2016 proposed order and supporting documents were riddled with at least
4 a dozen salient material falsifications, mischaracterizations and fraudulent misrepresentations intended
5 to deceive the court, which attempt was successful. Some of the major deceptions, stated briefly
6 herein include without limitation: 1) Gans falsely asserted that Remingtons continuing nuisance and
7 trespass allegations were foreclosed by the federal judgment because they involved identical
8 allegations, which is false on numerous grounds; 2) Gans falsely alleges here and for years that
9 Remington is asserting permanent nuisance and trespass, despite the dozen or more major motions
10 and declarations all electing continuing nuisance and trespass, since back before June 2011, because
11 the contamination was determined to be easily abatable then by reasonable means and reasonable costs
12 in John Aveggios remedial action plan (RAP); 3) Gans serially, fraudulently knowingly and
13 intentionally misstates the binding Supreme Court Mangini/Starrh/Beck /Spaulding/Kafka relevant
14 contamination law regarding the concept of plaintiff electing between permanent and continuing
15 nuisance prior to trial, depending upon the facts of the case which have been developed; 4) Also there
16 Gans deliberately omits the overwhelming evidence of remediability, concluded by all experts
17 including theirs, Ferriman, in his 2011 statements, and that is the only important factor which must be
18 determined. If Remingtons property is easily remediable at a reasonable cost than it is by definition a
19 continuing nuisance and trespass; 5) Finally, and of extreme importance, as are all of these
20 mischaracterizations and fraudulent deceptions, Gans has deceived and withheld from the court, which
21 does not do its own case law reading very often, that all controlling Supreme Court law on the subject
22 has determined that the finding of whether a given nuisance or trespass is continuing or permanent is a
23 finding of fact for a jury. Such a crucial finding is not for Gans to dictate or for the court to summarily
24 determine, based on nothing but bias, prejudice and gut feeling.
25 Q. On August 9, 2012 Gans blatantly lied in his Motion to Bifurcate the trial in his
26 Memorandum of Points and Authorities wherein he stated (page 3: 13-16) that Remington said that
27 the fill constitutes a continuing nuisance, because it contains migrating and leaching pollutants.
28 That purportedly causal statement is knowingly blatantly false on several levels, and then Gans goes
on to refute his own false statement (straw man) and in effect to entirely refute Remingtons continuing
455
1 nuisance allegations, which are not based on anything migrating or leaching but rather are based on
2 Mangini II and III, et al law. That law defines a continuing nuisance as one which can be reasonably
3 remediated at reasonable cost, which is the definition Remington has used since 2011.
4 Every one of these documents contains multiple material frauds and deceptions intended to
5 advance the RICO enterprises objectives as explained. Even with all the detail contained herein it is
6 actually not possible to fully explain all details of all of these complaints even in 1000 pages, which
7 will be next fully-developed under oath in federal proceedings as outlined, and it is strongly believe
8 that none of the named RICO defendants can or will maintain under oath that what they did was
9 legitimate, not deceptive and not fraudulently conspiratorial.
10 37. Gans enterprise clearly had fraudulent intent and committed overall mail fraud relate
11 to the extortive May 2016 release agreement between Farmers and Mathson:
12 A. As just previously outlined at # 36 above, John Mathson and Gans and presumably other
13 enterprise members have already cavalierly, materially and substantially violated the fence
14 building written contractual agreement, which as already further damaged Remington, by:
15 1) Allowing and literally leading at least 100 deer into Remingtons gardens through Mathsons
16 secret doors, where they predictably immediately ran all over Remingtonss land, ravishing his
17 roses and foliage in peak summer season, in flagrant violation of very express provisions carefully
18 drafted into the contract to avoid that very calamity. Remington has evidence of that from at least
19 three surveillance video cameras showing evidence of those acts over at least a two-week period;
20 2) Starting their fence construction prematurely and NOT Waiting until 60 days after resolution of
21 DR080678, as was very deliberately, intentionally, purposefully and carefully drafted into the
22 agreement, rather, defendants jumped-the-gun entirely causing the variety of damages and problems
23 discussed herein;
24 3) NOT COMPLETING THEIR NEW FENCE IN 7 DAYS, as required in the contractual
25 agreement. Defendants have now already worked on it prematurely for at least two weeks with
26 literally nothing, which means ZERO, to show for it yet, except for erosion damage to the
27 properties. Now some sort of a Monetary or evidentiary penalty for violation of said agreement will
28 need to be negotiated and established to compensate Remington for his damages, which considering
the present irreconcilable differences, will undoubtably involve damages attached to a future
456
1 broader action. How about if Mathson agrees to a moratorium on or temporary suspension of his
2 2017 fence vandalisms, burglaries and damages to Remingtons entire property? Since this issue
3 has been discussed for the last eight years, the chances of that happening are negligible.
4 4) Now causing the very damages and subsidence here, as this is written, that Gans just complained
5 about Remington not doing, in his nasty email and letter to Remington on and after August 22,
6 2016. Today, March 13, 2017, and also continuously for at least the last four months, there is and
7 has been substantial erosion and continuing damages occurring all winter long now on Remingtons
8 side of the Pulley line, which is all sharply downhill from where Mathson cleared a 4-foot wide
9 swath, and then dug an approximately 2-foot deep trench all along the border line. Is this a federal
10 predicate act or just another corrupt, careless and unethical contract violation as complained of in
11 the complaint below? Thats now up to the court to understand, interpret and then decide how to
12 adjudicate all of these dozens of disputes.
13 B. Said fence release agreement extorted Remington further, than what was described in
14 A above. By specifically and dramatically excluding all fraud, intentional misrepresentation,
15 defamation, slander, libel, malicious institution and prosecution of a civil action and related
16 causes for abuse of process attendant to prosecution against releasees and related frivolous
17 extortive fear-producing allegations, such as vexatious litigation, which defendants thrive-on
18 and laugh about as they beat-up Remington incessantly with them, defendants thereby directly and
19 STRONGLY threatened Remington once again with all of the above meritless causes of action.
20 The Gans enterprise has incessantly threatened Remington with all of the above since 2014 and has
21 already charged Remington with being: a vexatious litigant, which was summarily DENIED
22 by Judge Watson in 2014-15; and, with potentially bankrupting malicious prosecution in
23 DR080678, despite malicious prosecution already having been DENIED by Judge Reinholtsen in
24 2015, but totally undaunted and unimpressed, within two weeks of that denial, defendants promptly
25 and improperly reinstated it in early 2016, in DR140426. Those meritless extortive charges caused
26 emotional distress and eventually will be one of dozens of supporting facts for punitive damages
27 against defendants, or alternatively, implication of the RICO leadership, which could have the same
28 results as punitive damages verdict.

457
1 The most important part of Gans enterprises present overall extortive schemes are that they
2 will keep the pressure on with these frivolous causes of action indefinitely and until Remington
3 agrees to surrender ALL his land free, especially the critically important 1/3 acre which Mathson
4 has tortfully trespassed and encroached upon, and which he still occupies and refuses to
5 surrender today. Obviously, as long as Remington continues to resist Gans enterprise, he will be
6 continuously attacked by all of the above frivolous causes of action, which the enterprise can keep
7 filing indefinitely with their unlimited legal and financial resources.
8 Maybe all resistance is futile, but Remington, like the Federation nevertheless resists
9 Gans enterprises BORG-like invasions and attempted assimilation into their corrupt universe.
10 The Federation was losing badly to the BORG at first, however their will and Perhaps stupid
11 determination eventually turned-the-tide in those fictional Next Generation and subsequent
12 Voyager Star Trek chronicles.
13 In any event, defendants serious THREATS and attacks upon Remington under every
14 possible legal ruse, which began in summer 2008, has been unmistakable, difficult and costly to
15 defend and withstand, but most obviously will absolutely continue to occur, as long as all
16 enterprise members remain well-paid, and Lawrence and Allied stay highly-motivated and remain
17 determined to crush Remington into nothingness, or perhaps die trying, or perhaps more aptly die
18 defending himself against the enterprise.
19 As if once were not enough, after listing ALL the above fears and threats (in paragraph 4, page
20 4 of Gans said settlement agreement and release), carefully, painfully and with great emphasis,
21 which Gans has promised will be the basis of his next attacks, he repeats the exact same THREATS
22 and hollow frivolous accusations AGAIN in the very next paragraph, pages 4-5, SEE BOTTOM
23 OF PAGE 439 ABOVE , only this time in a slightly different, but equally ridiculous context. All
24 Remington now has to fear from Gans is fear itself and Gans over the last several years has tried
25 different tricks, intimidation, fear, numerous related pain-inducing destructive acts, and extortion
26 tactics every few weeks, most of which are quite successful, but have still not accomplished the
27 enterprises ultimate objectives yet. But, dont sell Skillings, Kishpaugh and Mathson, et al short,
28 they have not given up and quite probably have barely begun the fight, now that imprisonment
has become an option, which we always hope our next 60-second surveillance video will assure.
458
1 Gans has made a CAREER, and a lifes work,to date, out of these Remington cases and has
2 done very little else since law school. Plotz has literally done nothing else since law school, John
3 Mathson has done zero other productive work since 2008, and some of the others in the enterprise
4 have also made a lot of money here and spent a disproportionate amount of their time defeating
5 Remington.
6 Without Remington Gans and Plotz would and will be in a world of financial hurt for getting
7 any serious legal business in this town, because they are both rather inept, pretty ineffective
8 overall and cans comes across personally, as somewhat of a gawky, flaky nerd, trying to pretend to
9 be personable, and Plotz brings other major disadvantages to go along with his good looks, none of
10 which are presently relevant here.
11 Therefore, this RICO enterprise is a perfect gig for Gans and he probably will never get
12 such a perfect storm for his interests and ethics-less methods of practicing law in Eureka again,
13 and hopefully will never again harass another poor victim for 10-20 years.
14 C. Also, in said above-described settlement agreement, Gans conspicuously LEFT in
15 place defamation, slander and libel against the Mathsons and their claims for malicious
16 prosecution and abuse of process, as a very unsubtle, additional scare tactic, to get Remington to
17 continue cringing in fear and disappear here, taking NOTHING except a million dollars of costs,
18 property and personal damages and incredible time losses.
19 D. Additionally, Gans has already also violated CA Insurance code 1871.2 by
20 presenting and aggressively selling Farmers Insurance, a false, extortive claim in order to
21 induce them to ABANDON their representation of Bruce Remington and to pay the Mathsons
22 $20k to get out of future possible exploitive costs. Over the years, Gans effectively sold Harvey
23 Roberts who passed along the fear to Farmers that Gans Enterprises frivolous and false claims in
24 DR 080669, under the circumstances of these lawsuits, had a mathematical chance of prevailing. If
25 so, frivolous liability of as much as $80-500,000++ including, without limitation: fraudulent,
26 imaginary, inflated punitive and bogus emotional damages complained of by the Mathsons; high
27 expert and exhibit costs; Harvey Roberts high daily all-day attorneys costs, coming-up daily from
28 Mendocino, and then doing little besides providing emotional support to Remington in his unrelated
case Farmers was not defending or prosecuting. As explained elsewhere, Farmers made a rather
459
1 brilliant decision as things turned out and avoided at least $100-$200,000 in attorneys fees and
2 expert costs alone, by avoiding the four months of daily attorneys fees for the extensive pretrial
3 period, plus the SOL trial which never even got to the case Mr. Roberts was handling.
4 38. Remington now alleges a NEW second plagiarism count, 18 USC 1503, alleging that
5 Gans and Plotz intentionally misquoted and mischaracterized a federal judges Summary Judgment
6 Order for a second time. The first time was sufficiently described above and involved taking a
7 crucial federal judges order and changing about half of the words in a 17-word sentence to suit
8 their own inaccurate, false RICO purposes. This allegation, at number 38, is not very clearly
9 expressed below, but involves the RICO enterprises reprisal of plagiarizing a federal judge to
10 deceive a state judge, wherein they pretended that the magistrate had made numerous specific
11 findings of fact at summary judgment, when in fact he specifically made none, and therefore the
12 law demands that none be found. For a licensed California attorney to deceitfully argue otherwise
13 is deliberate fraud, plainly antithetical to easily researched California collateral estoppel law, and
14 was a deliberate fraud on Judge Reinholtsens court and Remington, which succeeded here greatly
15 damaging Remingtons case.
16 This allegation relates to the Federal Courts 2011 SJ ORDER which was disingenuously,
17 intentionally and improperly misconstrued and mischaracterized all over again by Plotz and
18 Gans in their 2016 pretrial MIL #20 proposed order and then knowingly falsely promoted to a
19 trusting Judge Reinholtsen. Several thousand pages of technical and somewhat superfluous detail
20 are involved here, so these few platitudes and generalizations herein will have to suffice now for
21 this court, as Gans, Plotz and their enterprise know ALL TOO WELL what Remingtons complaints
22 are her, and can attempt to respond accordingly.
23 Said MIL #20 order, as improperly plagiarized by defendants, was eventually adopted word-
24 for-word by Judge Reinholtsen who could not even correctly pronounce the chemical terms when
25 he read the order verbatim in court, in July 2016, and obviously relied upon defendants chemical
26 expertise, which was negligible and laughable. Related to all that in a variety of insidious ways,
27 we will next investigate and Discover further all of the background, justifications and
28 explanations that surrounded those events, especially in depositions, and including but not limited
to the subjects in the last four paragraphs of this section.
460
1 In those same repetitive pre-trial briefs, beginning in June and extending into August 2016,
2 Gans and Plotz deliberately ignored the well-settled concepts of continuing and successive
3 (nuisance), and Remingtons ABSOLUTE RIGHT (under California Supreme Court precedents,
4 such as Mangini I-III) to elect permanent or continuing allegations PRIOR to a trial. For said
5 attorneys to intentionally mischaracterize the determining law of this case and to flagrantly
6 misrepresent it to the Department eight court, who Gans and Plotz knew had not read it, and not
7 independently researched it, is clearly a serious ethical violation, if not more. Additionally, but not
8 really the RICO enterprises fault, although they have become the great beneficiary thereof, is that
9 Judge Reinholtsen does not really have the time or intellectual power to fully grasp the subtleties of
10 identical issues and collateral estoppel principles as defendants have fraudulently applied here, in
11 Remingtons opinion. Collateral estoppel is rather obviously a complicated doctrine in certain
12 respects, and as applied in these cases it clearly requires a more creative and intelligent mind than
13 what has been assigned here to resolve these issues justly, and which now will take either a state
14 appellate or federal district and/or appellate court to resolve properly, at least two Remingtons
15 satisfaction. Therefore, largely for that reason and also because the Northern California Superior
16 Court and state ethics system is too weak and unmotivated to enforce California attorney ethical
17 codes and requirements, Remington has been driven into this federal forum.
18 Getting the Department 8 courts full, unreserved agreement in July-August 2016, to bar
19 asbestos, all HCs and all pollution references, was supposedly, but in actuality, NOT based on a
20 Federal Magistrates entirely different ORDER and dicta. Here, the RICO enterprise pretended that
21 they were citing magistrate determined facts, when said magistrate never determined any specific
22 facts at all! Remington is just an old pro per, yet his research clearly showed the truth of the above
23 several paragraphs, and if he concluded that it is a certainty that both Plotz and Gans also did as
24 much or more research than Remington and would have concluded what an accurate an honest
25 statement of California law would be, just as well or better than Remington could do. Given that
26 rather obvious fact and in furtherance, Remington further infers that the RICO enterprise
27 deliberately deceived and confused judge Reinholtsen, knowing that they could get away with it
28 and did. Whether deliberately deceiving and confusing the state judge is an actual crime, and not
just something that any advocate would do if they could get away with it, is somewhat above
461
1 Remingtons present pay-grade, however the facts being what they are, during depositions of the
2 relevant parties, Remington will attempt to convert Gans and Plotzs intentional and knowing
3 deception into a federal predicate act as the RICO leadership predictably attempts to deny what
4 their intentional and successful deceptions and then to cover-it-up now.
5 All defendants did was to reassert Gans 2014 false (plagiarized) version of what the
6 Magistrate DID NOT say, but Gans wished he had said, only on steroids. In other words, once
7 again Plotz and Gans put his own self- serving words into the magistrates mouth about specific
8 state issues they wish to fraudulently eliminate, and therefore wrote a false script based on the
9 magistrates rambling, diffuse order, citing a bunch of defendants experts declarations which were
10 irrefutable in the federal case without any experts involved, but which were 100% refuted prior to
11 that in the state case. In other words, as fully explained in thousands of pages of mostly state
12 motion documents and declarations, said federal magistrate found no general ultimate facts at
13 all which might be collateral estoppel to anything in the state case, but merely discarded
14 Remingtons federal statutory claims for lack of expert evidentiary support. That was the only
15 reason that he granted summary judgment and it had nothing to do with any underlying facts or lack
16 thereof. The enterprises claims to the contrary were frivolous, intentional, obviously not just
17 innocent legal researching error, and therefore was a deliberate fraud on the state court, which has
18 severely damaged Remington to date and continues to do so.
19 In other words, to Remington, what Gans and Plotz did to confuse Judge Reinholtsen in 2016
20 rivaled what they did in 2014 (false plagiarized quotes of a federal judge to suit their fraudulent
21 purposes), was different but just as intellectually and legally dishonest and FALSE.
22 For some reason Judge Reinholtsen apparently did very little, and in any event insufficient
23 independent research regarding federal summary judgment law, and clearly and admittedly did not
24 really grasp what the federal magistrate actually did do under federal law, when it technically
25 dismissed Remingtons federal statutory claims, nor did he appear to understand how collateral
26 estoppel is handled between state and federal law and which law governed here.
27 Remington at one point even submitted 50 copied pages from his Walter Heiser treatise on
28 collateral estoppel, which apparently resolved all contested issues in Remingtons favor, however
the court did not read it, and commented that it already had lots of treatises. It further inferred he
462
1 didnt really need any treatises or especially understand their applicability here either, all of which
2 could be inferred as further 201 or 1503 collusion, corruption, or worse, however that is not
3 provable, yet.
4 Remington actually likes Judge Reinholtsen personally and is not making any effort to beat
5 him up, here. As explained elsewhere in detail, all the federal court judge really needs to know
6 about this incident is that Judge Reinholtsen said repeatedly over about three months that maybe
7 Im wrong about this but its my decision and now it can be reviewed by the appellate court. The
8 maybe Im wrong about this statement was made at least three or four times and at a minimum
9 indicated he was uncertain in his decision, as well he should be since it was highly abstract and
10 complex. Therefore, all Remington is saying here is how often does a judge say repeatedly that
11 maybe Im wrong about this? That is especially true here where we have a judge that appears
12 never willing to reconsider any decision and over eight years had always seemed absolutely 100%
13 positive and extremely decisive about every decision that he made. He also said at least twice to
14 Remington that he did not really care what Remington thought about his decision or feelings
15 towards the judge about several different other issues, however as to collateral estoppel he was
16 clearly troubled for several months and hopefully he still is troubled about it, as he now is deciding
17 what the future of DR 080678 is going forward.
18 39. 18 USC 1512, witness tampering, beginning with SKILLINGS, continuing with
19 Mathson, Costa, Kishpaugh and Joy Mathson, AND their entire Westgate GANG in August
20 2016, and now requiring and pointing to a much wider perjurious conspiracy among their
21 gang members in the next jury trial. As frequently stated herein, it will now be a simple matter to
22 force Gans and his RICO enterprise Associates to merely restate their state trial testimony and
23 swear in federal written and oral discovery that all of that was true and they will repeat that same
24 exact testimony in federal court. Once that has been done, the rest of this will be easy.
25 Skillings signed a false, inaccurate declaration originally written by Gans in 2010-11 to
26 refute Gans belief then that Remington was arguing permanent nuisance in DR080678, and to
27 resolve his Statute of Limitations and permission for trespass defensive problems, which
28 falsely claimed permission was intended to knock-out one of the fundamental elements of
trespass.
463
1 Skillings has been the heart of Gans defense since 2010, but when Remington argued
2 continuing nuisance and trespass, Gans had no honest answer, legitimate defense or truthful
3 witness. For years Gans appears to have planned to just somewhat modify Skillings 2011
4 declaration to conform to the facts he would need, however all that changed in 2016 pre-trial
5 hearings only 3-4 days before the inception of the SOL trial, however the court granted about a
6 week-off for Gans vacation and for a pre-arranged Remington business trip to Oregon.
7 Remington had recently discovered photos from 2003 which absolutely proved Skillings was
8 not only fully MISTAKEN in his times, dates and testimony, but was entirely discredited by said
9 photos.
10 Said clear, extensive and very conclusive photos proved that Skillings was not only
11 inaccurate, but had been lying in his Gans written declaration, and at a minimum had confused and
12 transposed what conceivably could have occurred in 2004-5, with events that never occurred in
13 1998. In other words, Gans fabricated story drafted for Skillings in about 2011 falsely and
14 incorrectly ascribed conditions on Remingtons property from 2005 back to 1998, which if proven
15 (as said photos DID) would have conclusively meant that Remington did not have any knowledge
16 of defendants contaminated dumping in 1998, and not until at least after 2005. Its rather
17 complicated to write clearly, but defendants absolutely know what Remington is attempting to
18 describe here, and it was important. Had the court allowed the photos which proved Skillings was a
19 perjurer, the dominoes of similar supporting perjury would have gradually fallen and Remington
20 would likely have won the SOL trial, proving that he did not reasonably discover any contamination
21 until 2006 at afterwards.
22 Remington was elated by that, and Gans panicked. At that moment, Remington had the case
23 won based on the merits and the truth, but made the enormous mistake of not concealing that
24 elation and perhaps gloating slightly. Gans being the slick and wily advocate that he is, and who
25 knows that Remington has always been truthful in these cases, unfortunately picked-up completely
26 on Remingtons confidence, integrity and excitement since he was only 5-feet away at the time, and
27 since we were sharing a big pile of incriminating photographs at the time, and very quickly went
28 back to his offices and drew up an entirely new disingenuous strategy based upon multiple
suborning of perjury and all of his trial witnesses.
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1 Gans who has sworn to destroy, defeat and crush Remington all at the same time, cleverly saw
2 instantly at that moment that his entire defense was totally ruined, he was ready to lose the SOL
3 trial and hence the entire case if he stuck to the truthful facts, and therefore he had to do
4 something drastic about it, and easily did so without missing a beat.
5 Ten (10) days later, going into opening statements at the August SOL trial, it never dawned on
6 Remington that Gans would abruptly turn 100% to criminal false testimony and perjury on all
7 material facts and with all of his witnesses, nor would Remington have thought that it would be
8 possible for him to coordinate all of that false material with the old fuzzy-brained John Mathson,
9 never came to our hearing for eight years, however Gans, Plotz, Brisso and Mathson proved
10 Remington wrong, very wrong. Surprisingly, they were smart enough to write, script, rehearse,
11 memorize and then believably repeat a series of fairly simple false stories which (ONLY) when
12 supported by five of their lying gang of perjurers, Remington was unable to refute them in front of
13 the jury. Gans additionally got a huge amount of help from the judge which Remington has alleged
14 must have been based upon some sort of biased or improper influence of one sort or another.
15 For example, Gans got the judge to BAR all of Remingtons crucial 2003 impeachment
16 photos, which Harvey Roberts had said would be absolutely admissible, which photos conclusively
17 proved that Mathson and Skillings were lying about what conditions were like on the properties
18 between 1998 and 2004. Those, and the series of other related prejudicial rulings by Judge
19 Reinholtsen to prevent Remington from using his important series of impeachment photographs
20 from 2003 during trial, probably caused Remington to lose the trial, almost more than any other
21 single action by said court, or caused by any single series of perjury coached by Gans. The
22 collateral estoppel and refusal to allow a Mangini II amendment of his DR 080678 complaint, after
23 eight years of changed facts, to elect continuing nuisance and trespass, and to explain the reasons
24 therefore, were also equally cataclysmicly prejudicial.
25 Therefore in summary, as explained above, just a few days prior to the trial Gans decided to
26 reverse course and take the very drastic action of no longer relying solely on Skillings, but instead
27 relying on a large series of gargantuan and material LIES from John Mathson on the key and most
28 important issue in the trial, which blatant and direct perjury was substantially supported by three (3)
of his drinking and drugee buddies plus his wife, as per #37 below. Said corroborating witnesses
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1 did notHere a word that was allegedly spoken, but merely swore that they could confirm that to
2 nonexistent conversations occurred during 1998, and Remingtons denial of that was insufficient to
3 overturn about 4 corroborating liars, backing up the BIG, gigantic lies by John Mathson.
4 Said drinking and drug-using buddies, plus Randall, Hilfiker and others, apparently going
5 back into at least the 1990s per John Mathsons admission of when he stopped drinking, are also
6 a quasi-gang along Westgate Drive. Mathsons gang is not identical to a Los Angeles prison gang,
7 but they share all of the most commonly known traits of a gang of rather odd class and racial
8 identity makeup and clear feelings of (generally justified) inferiority, plus common attitudes about
9 dogs and how everyone on the streets yard should look and be maintained. Their gang by
10 inspection is based entirely on race (Arian, ultra-right, Eureka born), often union membership,
11 lower class mentalities, plus lack of education, below average wealth (even on this street), below
12 average intelligence and obviously no erudite objectives in life, PLUS a violent response to anyone
13 who is different from that or them along Westgate Drive, such as Remington and his large estate, in
14 progress and far enough along where they can see where its going.
15 Otherwise, Mathsons gang is little different from a Los Angeles streets prison gang and their
16 hostility, quick-to-anger reactions, their bravado and perceived invincibility and above all their
17 violent and criminal nature. Unable to ever really be successful in life by their own skill or on the
18 merits, they have had to cut-corners, milk-out their Food Stamps and governmental services,
19 reportedly sell, and obviously use, a variety of upper and pain pill drugs, and destroy other
20 peoples property that they resent, especially and probably only where that person is Remington.
21 Now in at least their late 60s and up to 71, it is probably too late for any of them to ever do
22 anything honest, constructive or useful to society or anyone. As best we know, none of them go to
23 church, attend any organized social, charitable or recreational activities, and therefore attacking
24 Remington and tried to destroy what he has accomplished appears to be the RICO enterprises sole
25 purpose in life, primary reason for living and therefore achieving the RICO objectives would be a
26 great accomplishment for most of them, except their life would be hollow and empty without
27 Remington to beat-up-on, damage and hopefully destroy.
28 In August 2016, Gans further coached and suborned TRIAL PERJURY in his former star
RAO witness Skillings, as though Gans somehow knew the 2003 photos would be barred by the
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1 court, for unknown reasons, despite their just being used for impeachment purposes not for the truth
2 of what they portrayed. How did Gans know that Judge Reinholtsen would ultimately not allow any
3 impeachment photos against any defendants witness?
4 Skillings was called last, andIn spite of the knowledge of the photographs which proved that is
5 entire testimony was false, still he conspicuously made no attempt at telling the truth. Judge
6 Reinholtsen had seen all of the photographic evidence to know that Skillings was lying and not
7 telling the truth about anything, yet he allowed it and prevented Remington from refuting it.
8 Probably more than any other single problem at that trial, Remington was shocked and
9 disappointed that the trial judge new that a crucial witness was lying about everything and that
10 evidence existed that had been admitted into evidence by the court, yet it refused to allow it to be
11 used at all, let alone shown to the jury. That really shocked Remington and he still believes thats
12 unacceptable and adjust legal system.
13 Therefore, Skillings was still allowed to blindly follow Gans false script from 2011, now
14 totally obsolete, and that falseness was known to the court to Remington and to Gans, yet the truth
15 was kept from the jury and as a result Remington lost this case. Said judge saved Gans and did not
16 even allow Remington to pursue a perjury charge against Skillings, by prohibiting Remington from
17 using the 2003 photos at all. The 2003 photos proved Skillings had perjured himself, yet under
18 Judge Reinholtsens rulings the jury never saw, heard or read any intimation of that fact. He
19 allowed 3-4 into evidence during pretrial proceedings, but then oddly, inexplicably and without
20 reasons given would not permit them to be shown to anyone during the trial.
21 Those series of prejudicial decisions regarding the 2003 photographs alone set-up another
22 gigantic appellate issue, and arguably cost Remington the case there alone, plus there were another
23 5-10 almost equally massive apparent trial errors of similar case-losing magnitude.
24 The state courts prejudicial 2003 photographic evidentiary rulings eliminated Remingtons
25 absolute PROOFS of Skillings and Mathsons perjury, which proofs can now be made in THIS
26 court, with years to get the photos into discovery. Remingtons same honest, accurate evidence,
27 now known to all, including Skillings, but desperately barred in August 2016 by Gans, will now
28 conclusively work HERE. They will also work conclusively in DR140426 in the unfortunate
contingency that this case fails to go forward for some reason. This complex series of frauds
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1 perpetrated on the court by the enterprise, with or without the courts deliberate complicity, is
2 needed to prove several related PROMINENT predicate acts at the federal trial HERE, if not
3 before. This sequence of perjury by five conspiring witnesses, in combination with the 2003
4 photographs which are admissible here and used in tandem with the August 2016 SOL trial
5 transcript, will be conclusive in proving the lying, perjury and Gans suborning of same, when
6 properly handled in the various progressive discovery stages here, and in presently parallel case
7 DR140426, under Remingtons knowledge, expertise and with the assistance of his future trial
8 counsel, who can explain all this more clearly and dispassionately. Truth to Gans is like the noon
9 day sun hitting a vampire, but he cannot avoid it here, if Remington can avoid getting bush-
10 whacked in the Eureka darkness, over the next several years. The enterprise has laid the foundation
11 and/or planted the bomb within its basement which will rapidly lead to its imminent collapse. The
12 only real question now is who will remain in the building while it collapses and who will escape
13 beforehand.
14 Finally, under the August 2016 state courts coinciding collateral estoppel ruling and also his
15 (its) apparent leaning against their being a bona fide continuing nuisance or trespass here, without
16 the presence of hydrocarbons contaminating the groundwater (as per the courts erroneous present
17 findings, not as based on the fact but on an improper application of collateral estoppel), this series
18 of what Remington believes are errors by the court, plus the perjury suborned by Gans and all his
19 witnesses, probably have set Remingtons state cases up for an imminent appeal to resolve dozens
20 of these issues. However, the next logical step in DR 080678 would be a contamination trial
21 especially to resolve the continuing versus permanent election issue, which clear Supreme Court
22 precedents dictate is a matter for a jury and not for Judge Reinholtsen. February 17, 2017 is
23 expected to begin hearings and consideration of that issue. It DID, and said court is now making a
24 decision on that case based largely on insufficient written evidence but numerous Remington oral
25 remarks, which were right on point. Said court typically takes 2-6 months making difficult
26 decisions, which this one is because he needs to attempt to justify in writing a lot of very
27 questionable and probably erroneous rulings while he proves that he is still mentally qualified to do
28 his job and that an old pro per cannot interpret the law as well as he can, so that he can make a

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1 credible showing in the appeals court. Therefore on balance, Remington would expect a ruling here
2 after May 15 but quite probably before June 15.
3 This Federal case has been attempted, among many reasons to: 1) circumvent that lengthy
4 state appellate process by introducing the allegation of a RICO enterprise, which will also be
5 amended into the state complaints as required; and, 2) also getting a clarifying ruling as to collateral
6 estoppel and what can reasonably be applied here from the 2011 technical and peremptory Rule 26
7 and 37 federal summary judgment.
8 40. 18 USC 1512, Felony witness tampering by Russell Gans at and during the state SOL
9 trial itself in late July-August 201636. That witness tampering and perjury will be provable in the
10 next state trial, or the first federal trial now that there is sufficient time to get all required evidence
11 admitted such as the 2003 photos into cross-examine all of the perjurers using omission
12 techniques, plus a lot of believable advance notice throughout Voir Dire will be provided to the next
13 jury, about what has happened already and what they can expect here next.
14 If this Court goes forward with a trial HERE, Gans will now HAVE to settle these cases away
15 somehow, because they will all go to jail if they attempt to repeat their state perjury seamlessly and
16 consistently in Federal court discovery and related proceedings, or even to repeat it in state
17 discovery in DR140426 against Remingtons several years of study, preparation, intense focus on
18 this grave injustice and practicing cross-examination by omission this time. Additionally,
19 Remington plans to use experienced trial counsel, as or when needed. Simply put, as explained
20 above and throughout, if Gans and his enterprise members swear to all of their previous lies and
21 mischaracterizations, so far set forth in the state court record, they will become susceptible to or
22 open themselves up to serious federal criminal charges.
23 36
Allegation #39 pertains largely to Skillings, and his continued perjury committed around the
24 first week of August 2016, which was begun in a false declaration in 2010-11, but also explains
the overall Gans conspiracy for all of his trial witnesses to commit perjury. #40 pertains primarily
25 to the perjury conspiracy among Gans five witnesses during the trial itself, during the first two
weeks of August 2016, An overlap somewhat with #39 and #41. #41 pertains largely to the overall
26 planning of this perjurious conspiracy and how and when Gans first had to change his entire trial
27 strategy and opening statement during the second half of July 2016. There is some overlap
between #39-41 which will be cleaned up and better organized in the next version of this
28 document. There is no specific cause of action alleged here for defendants known serial
perjury, however it will be highlighted and proven shortly in federal discovery and then used
to repudiate witnesses at the next trial, whether state or federal.
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1 Many of their state witnesses and other participants in that trial, who know they are, or
2 very quickly going to open themselves up to possible federal imprisonment if they persist with
3 their corrupt racketeering enterprises unlawful intentions and objectives.
4 Again, if Remington is seriously injured or killed, this entire enterprise will collapse like a
5 sand castle hit by a really big wave.
6 In this RICO case, Remington will heavily employ the 2016 trial transcript versus defendants
7 2011 incompatible (contradictory) Special Interrogatories and declarations (signed by Mathson
8 under penalty of perjury and drafted by Gans), again shockingly barred from the jury by Judge
9 Reinholtsen in another apparently prejudicial ERROR. Whether those errors stand-up in state
10 appellate court, or not will be irrelevant, if they are used fresh in this case, where they are all fully
11 disclosed and fully deposed.
12 Brief details of Gans corrupt RICO 2016 SOL trial:
13 The odd story of Gans August 2016 SOL trial began with complete surprise and a full
14 departure from the previous eight (8) years of tens of thousands of pages of case records, much of it
15 sworn from Remingtons side. Gans led-off with an entirely unethical and false Opening
16 Statement, which revealed his primary perjurer-in-chief, John Mathson. Mathson was further
17 surprisingly supported, unexpectedly for the first time by perjury suborned in FOUR (4) additional
18 corrupt supporting witnesses, Joy Mathson, Kyle Skillings, Joe Costa and Jon Kishpaugh, which
19 violated state and federal law. That now provable perjury, can and will occur in the next trial here,
20 with several more years to gather appropriate evidence and prepare.
21 Said ancillary supporting perjury all supported Gans MAIN material perjurious witness
22 JOHN MATHSON, on the ONLY material issues to be determined in that 2016 SOL case. They
23 were: what Remington saw, knew, when he purportedly saw and knew it, and what he should
24 have done as a result of seeing anything at all in 1998, had he actually seen what defendants lied
25 about Remington seeing. The truth here is that Remington actually saw nothing in 1998, because
26 he never went over there to see anything (EVER, in any year) and was totally preoccupied with
27 his own extremely complicated affairs for the next several years. Eventually, when he was able to
28 develop and excavate the dumpy areas, as extensively explained. It still took several years to
discover the enormous buried, largely odorless and invisible contamination which was further
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1 concealed for many years by massive brush piles, blackberries and a 6-inch deep layer of redwood
2 needles.
3 Remington saw nothing in fact, in 1998, and never visited Mathsons property, to even talk
4 across the fence, until at least 5 years AFTER 1998; but, even if he had seen what defendants
5 falsely claimed that John Mathson had showed him, the courts accepted bad jury instructions
6 clearly did not dictate that Remington should have then immediately been put on notice to spent
7 $50,000+ investigating and looking for concealed, invisible and odorless deeply-buried and initially
8 unknown and unsuspected hazardous materials.
9 There have now been multiple REAL, serious state predicate acts committed here already,
10 which possibly on the basis of their state perjury being converted into federal perjury, as explained,
11 may be enough to send 5-6 people to prison, but in any case they will be sent to prison when or IF
12 they begin repeating ALL their false sworn testimony related to all of the subjects herein, orally to
13 state and federal criminal investigators, and/or in and during the imminent and extensive written
14 and oral federal discovery now being planned to be conducted over several years, in preparation for
15 the Federal trial, or alternatively the next state trial.
16 41. 18 USC 1503 and 1512, Obstruction of Justice and Witness Tampering around July
17 15-25, 2016: Gans advance planning, enormous surprise to Remington and the corrupt
18 changes to Gans entire trial plan a week before opening statements. Although overlapping
19 somewhat with the two previous sections, #39-40, this section pertains to and focuses largely on the
20 dominant role of John Mathson in the Enterprises 2016 trial perjury conspiracy, and how it came
21 about that Gans had to replace Skillings foundational role with Mathson because the former had
22 been fully discredited with and by the 2003 photographs.
23 The weekend before the SOL trial started, Gans wrote a simple false, perjurious script for his
24 ventriloquists dummy, John Mathson. Gans elaborate, 2-3 months in the consideration, education,
25 coaching and the making, involved daily intense rehearsals of John Mathsons planned trial
26 testimony, which were viewed by Remington for at least an hour per day for 100 days in 2016. To
27 and from the courtroom, in the elevator, before the courtroom was unlocked and for 20 minutes of
28 breaks each day, Gans was constantly discussing this case and John Mathsons potentially star role
in it, endlessly rehearsing the false, fictional facts on the central issues.
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1 However, it is now believed that Mathsons central perjury in the SOL trial was not well-
2 planned until it became crucial in late July 2016. For about 100 previous days during the pretrial
3 hearings, while Mathson just sat their watching and listening, there was never any inkling that he
4 had conclusive false testimony to offer that purportedly would fully refute everything that
5 Remington had been saying and testifying to under perjury for almost one hundred days! Never a
6 mention or an inference of such testimony was ever revealed for eight (8) years including in
7 numerous sworn opportunities to do so, prior to several other scheduled trials, and Remington
8 therefore concludes that said false Mathson testimony was not even contemplated or scripted until
9 late July 2016. John Mathsons resulting calm, psychopathic LIES about walking the fill with
10 Remington in 1998, NOT JUST ONCE but TWICE,(When the correct honest number was ZERO)
11 were therefore well-rehearsed, well-executed and shocked and surprised Remington during trial
12 Opening Statements, as was intended.
13 Gans lies were so brazen in their illegality, desperateness, brashness, and overwhelming
14 over the top conclusive magnitude, that they were not fully refutable by Remington, on the fly
15 in 5-days of cross-examinations, without sufficient preparation or experience for handling such
16 perjury. As above, when Remington discussed some of this with Harvey Roberts over the telephone
17 he got the impression that Roberts was just as staggered and shaken as Remington was and
18 probably would not have had a very effective response either in real time.
19 As explained elsewhere, the main reason that Remington was shocked by the Mathson material
20 perjury in support thereof was because not one word of that was ever disclosed previously in many
21 hundreds of pages of sworn documents and depositions where that topic and all aspects of it came
22 up repeatedly. Thats where the cross-examination by omission comes in.
23 During the federal proceedings Remington will have to go through that deposition and find all
24 of the 50 places that Mathson could have accused Remington of having been over there to see the
25 fill in progress, which occurred during the 2010 depositions where Remington was doing most of
26 the interrogation. Mathson had his chance to swear to what the truth was for many consecutive
27 days, and ironically thats pretty much what he did do. Therefore it is now Remingtons job to
28 onerously go through all of the prior testimony to determine why his 2016 testimony was 180 from
anything Mathson ever said in the case before. Never was the above subject, first invented and then
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1 presented out of total desperation, for the first time nine years into this litigation, even hinted at or
2 addressed; and, similarly never was Mathson angry with Remington at any deposition for asking
3 questions about what we supposedly talked about in 1998, as we were walking on the fill, etc.
4 The reason that none of that ever occurred was because Mathsons whole fantastic account of
5 two visits by Remington and walks on the fill, etc during the project was a total fabricated bunch of
6 BS. It may take four-solid days, or four solid weeks, but in front of a federal civil or grand jury
7 Remington expects to make that case very forcefully, very logically and very convincingly, now
8 that we know what a lying dirt bag Mathson really is. If his wife joins in with that perjury we will
9 Have to enthusiastically tear-her-a-part also.
10 The Court was not helpful either, and apparently decided to side with its TWO former law
11 partners a couple months previously beginning on June 2, 2016, and clearly also overtly determined
12 that Gans was telling the truth and therefore Remington must not be, and that kind of prejudicial
13 conclusion by the pleasant, courteous and charismatic court, inescapably was fully transferred to the
14 jury to Remingtons detriment.
15 Also, Remingtons cross-examination experience, deposition preparation, resourcefulness and
16 his organizational skills and energy at age 75 were also slightly insufficient to fully deal-with and
17 convincingly refute such overwhelming SURPRISE perjury. Discovery is supposed to eliminate
18 surprise, but Gans RICO corruption and deceit easily overcame all proper California trial advocacy
19 standards and therefore totally surprised Remington by introducing a huge mass of evidence which
20 should have been disclosed in special interrogatories but was not. It was not because it did not exist
21 during disclosures in 2011, but was a total 2016 creative fabrication, which the court inexplicably,
22 except for the reasons inferred herein, let slip-by to Remingtons great prejudice. Being in pro per
23 was a Big disadvantage, however as above, even an experienced trial lawyer like Harvey Roberts
24 with over 100 trials on his resume, would not have substantially altered the result here, due to the
25 extreme surprise and extreme difficulty of one avid witness overcoming five calmer and more
26 relaxed, experienced psychopathic lying witnesses.
27 Said perjury simply involved Remingtons word against one personable, honest-appearing
28 Gans plus ONE (1) ordinary Eurekan, Solidly backed up by four others; and, the jury proved to be
MORE like, (and clearly found them more trustworthy and likable), Gans and the 5 perjurers
473
1 than Remington in education, temperament, class and disposition, and thus believed the later. In
2 other words, this was a jury of Mathsons and Gans peers but not Remingtons. The original
3 four members of the jury pool which shared some of Remingtons values and important traits were
4 all immediately screened and quickly discharged. Gans eventually WON the SOL trial
5 unanimously, because the jury liked Gans and his witnesses and not the old pro per Remington
6 and his slower, uneven, delaying and complex presentation, WHICH HAD BEEN
7 DISINTEGRATED BY SURPRISE, and where the jury instructions were totally inadequate and
8 also where insufficient and ERRONEOUS instructions were Actually given to them, in
9 Remingtons opinion. As explained above, nothing about subterranean pollution or what mightve
10 put Remington on notice to do $30,000 worth of investigations because of a little benign dirt that
11 rolled down the hill. That small amount of be nine dirt is the worst case scenario for Remington and
12 is based on their false facts, because the truth is that Remington saw nothing at all. However had he
13 actually seen a few wheelbarrow loads of clean dirt as alleged by defendants, that would certainly
14 not have put him or any prudent person on notice to do anything or spend a dime.
15 Remington had not gone near Mathsons land in 1998, or ever spoken to him on it, at all,
16 EVER until after 2004, but the jury WRONGLY believed Mathson, which shows no justice system
17 is perfect or even close in this case, against a RICO enterprises overwhelmingly corrupt planning,
18 witness coaching, intellect, and utter lack of attorney ethics, allergy to all truth, which was all
19 supported by unlimited financing and effective cheerleading from the several Mathson women, who
20 daily staked-out a full row in the audience.
21 42. Still continuing chronologically, further 18 USC 1951 extortion and thinly veiled
22 THREATS, this time in bad joke form: ...maybe hell die next time....
23 At about noon, while walking to his car after one of the very last pre-trial hearing days during
24 near the end of of July 2016, on an exact day which Remington would have to try to reconstruct
25 from his detailed pretrial notes of that time, Remington unexpectedly caught-up with defendants
26 trial team waiting for the light to change at fifth Street where we were all going south. Evidently,
27 Remington surprised them by packing-up his trial materials and evidence very fast one day and
28 unnoticed by them caught-up to the Gans/Plotz/Mathson trial trio at the 5th Street crosswalk traffic

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1 light, rather than usually being about 1-2 minutes behind them, as we always headed up I Street
2 towards Remingtons car and the RICO offices at seven Street.
3 A few seconds before they realized Remington was nearby, and rapidly gaining-on them, and
4 simultaneously as Remington had also started to cross 5th street 8 away, ahead of them, and
5 BEFORE the light went green, Remington overheard the end of the following defendants
6 unreserved, private little jokes:
7 Gans, who usually does most or all of the talking, had said: ...maybe hell die next time...,
8 or we can try something else..., with audible laughter from Plotz and Gans at least, as Mathson
9 always seems quiet and sullen, but probably he smiled and may have laughed softly and politely. If
10 so, that was not clear, because Remington was watching for traffic and was already halfway across
11 fifth Street by then, against the light.
12 Discovery will probe that entire conversation, what the exact context was, in case that was
13 relevant and what or who that little inside joke was directed at, if not Remington, but Remington
14 inferred at the time and based on the previous heated pre-trial hearing context, that Gans little joke
15 probably referred to the series of Remingtons serious illnesses caused by the contamination from
16 2013-15, and clearly killing Remington by whatever means it takes is their preferred option.
17 Remingtons failing health and dump-caused illnesses have become an important and material issue
18 in these cases. In any case, whomever defendants were laughing about that might die next time
19 certainly gave them lots of relaxed enjoyment, and actually increased the extortive pressure on
20 Remington further, since as alluded to above, the Gans enterprise appears to have no ethical,
21 reasonable and honest legal path to victory here, hence they had to and did GO BAD completely
22 during 2016. How many more serious crimes or WHAT violent acts the RICO enterprise will now
23 decide they have to commit to preserve their survival, remains to be seen in the future years.
24 In any case, now fearing for his personal safety, in November 2016 Remington invested in a
25 new batch of unbranded surveillance cameras, direct from China for about 70% off plus a
26 dozen 32 gb chips and (the new HDSC) card adapters for at least 80% off the prior prices of $10-14
27 each just last year, also, if one can wait for delivery direct from China. About 90% of this RICO
28 statement is partially obsolete because it was written many months ago before some of these facts
evolved, were properly understood and before hundreds of major specific document and factual
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1 discoveries were made during 2017. Therefore, as explained, this document will begin a major
2 revision almost before it is filed and served
3 43. John Mathsons 1951, Gans ordered vandalistic torturing of Remington, their
4 bullying, and protection racket extortion continues through todays date, 12-31-16, literally,
5 and also through the date of this final proof read which is March 13, 2017.
6 John Mathson is a typical shy, meek, sullen, admittedly very depressed, uncreative,
7 unassuming, formerly personable when he was younger, non-initiative taking family soldier and
8 as such he is unlikely to commit additional criminal acts on his own authority and without Gans
9 orders and privilege protections. From Remingtons experience, John Mathson has rarely ever
10 done anything on his own, depends on his gang members, Gans and especially his wife Joy to
11 initiate any kind of action, or initiate any kind of exercise or project such as bringing in some
12 firewood or to execute any specific plans of any type or any intentional activity to do anything,
13 besides sit in front of his television, or ride on his riding lawnmower. The only possible exception
14 to that would involve Mathsons enthusiastic enjoyment of his massive and continuous vandalisms
15 of Remingtons property, so during discovery an attempt will be made to determine whether most of
16 that was done at Gans behest and under his specific orders for specific days, or whether Joy
17 Mathson kicked-his-ass out of the house and that prompted many of his 1-2000 hostile surveillance
18 walks to show his dominance and fence sabotages, etc. Alternatively, did John Mathson just do
19 some of that on his own volition for the fun of it, or was it most likely some combination of those
20 three possible motivations?
21 Gans gives all the orders here, and has since 2007. Mathson himself acknowledged that on or
22 about December 28, 2007 when he said: All this is out of my hands now. Gans is now keeping
23 the extreme criminal pressure on Remington, which continues in October, now November 20,
24 2016 (and then now, again into March 2017), with an elaborate series of holes in Remingtons
25 South fence discovered about October 29, 2016. Later, and additionally two additional, NEW big
26 holes were discovered around November 11, and 15th, and repaired the same day. Prior to 10-29-16,
27 Mathson crawled through dense brush and a very solid established 30 tall privet hedge to remove
28 some non-climb fencing and a 50# burl slab blocking the passable channel between two mature
privet hedge trees, planted only 20 apart. That is enough for deer, bear and Mathson to squeeze
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1 through, which they all DID. But NONE of these examples is ever the LAST criminal act (as
2 written 10-30-16). As Gans and Mathson both well know, because Remington has written at least
3 100-pages under oath about the topic, and every Mathson-cut hole cut in a Remington fence allows
4 dozens of deer plus usually many bears to enter Remingtons delicate, rare and sensitive gardens,
5 which said ravenous beasts cannot get into to damage otherwise.
6 Two weeks later when going over this very early draft, there was a new gigantic hole cut in
7 Remingtons 25 tall hedges and fence on November 11, 2016, which Remington randomly
8 discovered after collecting surveillance cameras, from the Mathson side. At dusk, as Remington
9 removed a camera from a tree near the Mathsons line he looked-up to see a giant deer slowly
10 ducking through a gapping hole into Remingtons gardens. Since two cameras (with their full 32
11 GB videos, about 500 30-60 seconds long) were missing, and presumed stolen by Mathson,
12 Remington had missed that fence hole in the twilight, and he walked right by, 15 away from it. On
13 the day of this final proofreading, March 13, 2017, Remington noticed just this evening that one of
14 his surveillance cameras 10-feet inside his difficult to enter but not locked front gate had been
15 altered, and the setting had been changed from 60 second video to single photographs, which
16 setting would be a very simple way to defeat the system by: Activating the motion sensor by
17 making any sort of motion, such as by throwing something towards the camera, and then
18 committing the crime during the 60 or more seconds between shots, while the system resets itself.
19 Additional Damages have been caused by the enterprises vandalisms, during the Christmas
20 holidays as per usual, either executed by Mathson, Skillings, Kishpaugh or one of the other soldiers.
21 Remingtons gardens are still in full flower, leaf and rose bloom, even today in late
22 November, and again today in March, 2017, and thus considerable damage can and will be done
23 by that one or more deer in a few days.
24 Although not fully listed herein, Mathsons vandalisms have continued and been documented
25 in various manners, into January 2017.
26
27
28

477
1 44. As described above at #39-40, Mathson37 has now taken to watching carefully for any
2 Remington surveillance camera and then stealing the surveillance cameras themselves and
3 their 32 gb chips, presumably especially when hes done something incriminating which might
4 have been recorded.
5 Mathson was all over Remingtons yard from August 12th-18th, and then into September-
6 October, furiously clearing along the property line in preparation for his grossly premature fence to
7 be installed by Miller forms nursery; and, that furious premature fence work also involved
8 additional removing any incriminating evidentiary objects which he found along the way, as
9 explained above. Mathson further damaged Remingtons property during those visits as recorded
10 on various surveillance cameras. That was also the period when one of Remingtons $100
11 surveillance cameras went missing entirely, including the incriminating videos on its CHIP, and
12 was presumed stolen. Possibly Miller Farms may have also made a supervisory visit during August,
13 but it is very unlikely that they had any interest in stealing a surveillance camera, one of which
14 cameras will eventually send John Mathson to Pelican Bay state prison, or perhaps a federal facility.
15 Inferentially, that camera probably had recorded videos of multiple FELONIES and another
16 camera was found laying on the ground in another area, far from where it had been hung on a
17 TREE, with its chip REMOVED, also. Inferentially again, presumably it had captured significant
18 Mathson crimes of vandalism, so the evidence was removed and SPOILED. Seems like maybe we
19 have a pattern developing here, so Remington will have to start putting the cameras 20-feet up
20 trees, again, off of ladders.
21 Well ask Gans and Mathson, but we dont expect to see either missing 32-GB chip again,
22 with hundreds of hours of surveillance video on each. Remington recently ordered more cameras
23 and chips directly from China, (in November and now mounted in 2017) as prices are down
24 drastically there, as above. Stealing Remington surveillance cameras and half-full 32 GB ships is
25
37
4. Although overly detailed no doubt, all this will be helpful to Remington and future
26 principles in these cases to understand these crimes exactly. John Mathson is wily, wary,
27 observant and clever like a common street house-burglar. He has noticed and Remington has
personally explained his complex security network along the Mathson border during pretrial
28 discussions, so Mathson went back to the opposite (Cooksey side 750 away) southern fences
where there is plenty of hiding brush and no cameras, yet. Probably that was Gans idea since he
is the REAL Moriarty, and long-time daemonic mastermind here.
478
1 probably NOT a federal racketeering act in itself, but certainly is a state crime and with enough
2 cameras well catch the perpetrators in the act before long. As explained throughout these
3 documents, even the Godfathers Mafia organization does some petty crimes which in themselves
4 would not send anyone to prison, but they do incriminate the perpetrators somewhat, and
5 become part of their overall body of work, in preparation for their serious arsons, kidnappings,
6 murders and extortion crimes
7 As to locating, defeating and/or stealing surveillance cameras which are known to possess
8 incriminating footage, WOULD WE EXPECT ANYTHING LESS from a mafia soldier like John
9 Mathson, while waiting for orders from Mr. Big for something more destructively loathsome and
10 fearsome? Everything Mathson, Gans, et al do concerning Remington is at least unethical, often
11 corrupt and sometimes criminal on some level or another, either minor or very major.
12 45. 2016 Violations by John Mathson of 49 USC 5101, et seq and 15 USC 2607, 2614,
13 2615 and 2642, which are various pertinent hazardous materials hauling laws.
14 In addition to the proven and absolutely established material evidence spoliation, captured
15 on still and video surveillance, John Mathson has recently and during 2012-2016, violated asbestos
16 and hazardous materials laws further here by:
17 1) Removing asbestos pipes and Chrysotile excavated evidence from Remingtons land
18 during 2016, flagrantly, clearly and incriminatingly caught on surveillance video;
19 2) Then he either secretly stored it on his land illegally, behind two locked gates, where it
20 will still be stored, covered and concealed, but found when we investigate imminently; or
21 3) Putting it in his household garbage can for routine pick-up; or,
22 4) Hauling it unlawfully, as usual, on his own utility trailer to some unsuspecting local
23 ordinary dump, where he then proceeds to dump dangerous hazardous wastes into an unsecured and
24 improper facility.
25 WHICHEVER procedure he followed, as will be queried, looked-into and then thoroughly
26 investigated during future routine Discovery investigations, it was unlawful, on multiple levels,
27 including the federal level;
28 46. Ever since 2008, Gans and Mathson have also violated and reduced Remingtons
inalienable due process rights (42 USC 1983) and damaged the Burl Trees value and
479
1 ability to function as a business by complaining to, and causing the continuous frivolous
2 harassment from more than 40 governmental regulators, without one of defendants literally
3 hundreds of complaints ever proving valid, fruitful and/or non-frivolous in basic substance. At least
4 we have made a small amount of progress here, in that Gans and the Mathsons made so many
5 frivolous complaints over the years that now they are effectively disregarded for crying wolf too
6 many times and for too long. Remington has no doubt that those complaints continue, while
7 Mathsons local gang hangs around on their driveways, posturing, looking mean and tough while
8 trying to stare him down and make him uncomfortable enough to leave this street; but, none of
9 those more recent complaints have been relayed to him through any governmental authorities for
10 more than a year now certainly, and are presumably disregarded as irrational crank calls..
11 As above, those seriously harassing and frivolous complaints are summarized in some of
12 Remingtons color, projectable trial charts, attached as exhibits to this complaint, now in Volume
13 III. Other than burning several cardboard boxes in 2008 (a month ahead of Remingtons planned
14 voluntary removal schedule), no Mathson complaint has ever led to any actual valid actions, by
15 Remington or any authorities, after an initial investigation and waste of all involveds time and
16 anxiety. The cardboard boxes were burned at the suggestion of County planning in order to end that
17 particular battle sooner rather than later. California Fish and Game fully exonerated Remington for
18 putting debris into Remington Creek and in fact are now a witness against the RICO enterprise
19 for THEIR Multiple contaminations of said Creek by hydrocarbons, asphalt, bacteria and a plethora
20 of other toxins , and the initial water diversion permit they thought was required, turned out not to
21 be an issue at all. In fact, overall looked at in perspective today, not unexpectedly, Mathsons
22 complaints mostly just caused Remington a lot of trouble and emotional distress and will eventually
23 mostly be turned-back on themselves, causing much more damage and financial problems for
24 themselves than for Remington in the final analysis.
25 When a one-man manufacturing, research and sales business has to spend FULL-TIME, every
26 day interviewing investigators and escorting them around Remingtons large property, little to NO
27 FRUITFUL WORK gets done on those days, which here, eventually totaled many hundreds of
28 days.

480
1 Remingtons business working-time has always (since 1970) been worth at least $1000 per
2 day and at times up to one million+ dollars a day, on the 8 or 9 days when he negotiated, sold
3 himself, and procured the gigantic, lucrative 7-8 of the largest burl contracts ever drawn up in
4 Northern California certainly, in an average of several hours of time each, with said above contracts
5 worth an average of at least several MILLION dollars each two Remington, again, according to
6 easy, detailed trial or deposition proofs. Remington personally was only able to obtain several
7 million dollars of value each from said contracts, however were the Burl Tree a more massive
8 international exporting operation, or if the market had been much bigger back then, most of those
9 contracts could have been worth as much as hundreds of millions of dollars in terms of value of the
10 product made available for little or nothing, if the sales market had been that large, which
11 unfortunately it was not.
12 In other words Remington, logged and took all of the burl that he could reasonably sell in
13 each case, but typically left 20-98% of what was also readily available right where it was, oftenLeft
14 sitting by a location where it could have been easily loaded, but was not because it was too
15 expensive to remove it without a definite market for it.
16 Here, defendants have for many years deprived the Burl Tree of its sole source of survival,
17 Remingtons liberty and/or working time and in so doing, they eliminated his high-level burl-
18 cutting, milling and finishing, burl logging and related new product developmental WORK, for
19 months at a time, breaking all continuity with his customers and sales, and losing millions of dollars
20 ultimately, JUSTBecause Remington needed to defend against Mathsons and Gans frivolous, now
21 settled, as above, 2008 lawsuit, DR080669, alone.
22 47. Defendants are also reported and believed to have violated 42 USC 102 in dealing
23 with controlled substances, specifically marijuana, opiate pain pills and amphetamines, over many
24 years and especially the four (4) that are relevant here. Remingtons odor-evidence, frenzied,
25 unkempt visitors coming and going at all hours of the day and night, and similar related anecdotal
26 information, nearby neighboring complainants and other knowledgeable and/or interested
27 witnesses will be investigated and interviewed during discovery herein, or sooner as time permits
28 related, and related to WHICH non-Westgate residents, RAO workers, Olson relatives, and/or other

481
1 enterprise soldiers were involved, in addition to the Westgate Drive RICO defendants and alleged
2 dealers.
3 48. 18 USC 1512, additional witness tampering of Remingtons trial witnesses.
4 As complained of above, it has become apparent that Gans and his enterprises confederates
5 spend more time on the phone calling, influencing and/or intimidating Remingtons trial witnesses
6 than he does himself. Matt Filiar was our photographer witness that was employed by Harvey
7 Roberts and Farmers Insurance Company, but he also did some definitive photographic studies on
8 these properties which proved that Madison committed blatant perjury in his depositions.
9 The issue Filiar had investigated and where he is planning and scheduled to directly
10 contradict Mathsons serial perjurious testimony concerned photos which John Mathson claimed he
11 took from outside Remingtons property; however, our expert Mensa photographic analysis
12 conclusively proves that each of the five (5) shots selected for analysis all had to have been taken
13 from well-within Remingtons property and could not have been taken with telephoto lenses, or by
14 any other means from anywhere else. That means that John Mathson committed perjury on that
15 issue as a matter of science, a priori, irrefutable fact and hence conclusively as a matter of law.
16 This was originally a major 2010-11 trial issue intended to prove John Mathson was a perjurer
17 about those photographs, about his denial of frequent trespasses into Remingtons property in order to
18 take photographs, sabotage equipment and/or steel the inventory and equipment complained of above,
19 and therefore Filiar was a major witness to refute the integrity of John Mathson, and he still is.
20 It is now well-known that John Mathson lies about most things and committed many hours of
21 serial perjuries in the August 2016 SOL trial, but in 2008-11, Filiar had definitive and positive proof
22 of Mathsons perjury about many material case issues.
23 Therefore, when Remington called Filiar on the phone and also emailed him, repeatedly in
24 summer 2016 to enlist his testimony in the August SOL trial, he discovered that Filiar was
25 somehow no longer interested and that Gans and his agents had managed to reached him, and
26 scare him as they have reached nearly all of Remingtons witnesses before they can be used at a
27 trial. With Filiar they deleteriously influenced him, THREATENED HIM with some sort of as yet
28 unspecified dire consequences if he continued to testify on behalf of Remington, and therefore he
was and still IS now afraid to testify against Gans RICO enterprise. During the trial, however,
482
1 Remington did not yet have time to fully discuss exactly what happened with him to shake his
2 resolve. Hopefully, with time to calm Filiar down and to explain to him the importance of bringing-
3 down this corrupt enterprise, Remington hopes to bring him back onto his expert team. So far,
4 Remington has not yet been able to determine all of the details, dates, possible bribes, threats,
5 intimidating statements and/or specific coercive extortions which took place against Filiar, but will
6 do so imminently, during discovery here.
7 49. 18 USC 1957, BARS any defendants from engaging in any money laundering
8 monetary transaction, with corrupt dirty money in criminally derived private property, that has
9 a value greater than $10,000; knowing that the property is derived from unlawful activity, and it is
10 in fact proven that the property is derived from unlawful activity. All of the primary RICO
11 defendants are accused of purchasing major real estate with a value over $10,000, during the last
12 10-20 years, and specifically and especially RAO, Rich Olson, Skillings, Gans and John
13 Mathson. Presumably others will be added during discovery.
14 Given the highly corrupt and alleged numerous criminal activities of that group during the
15 relevant time frame, it is believed that any real estate purchases, modifications to existing real estate
16 or remodelings and renovations of any kind exceeding $10,000 would have been barred under this
17 statute, either wholly or in part, due to the amount of dirty, laundered money in the hands of and
18 being a lavishly spent by all of those defendants during the last 20 years.
19 Logically, if any significant portion of a $10,000 or greater real estate purchase involved
20 laundered money, it can be assumed that the purchase would not have been consummated but for
21 the dirty money, and therefore the real estate was purchased effectively completely or at least
22 substantially by laundered money, as governed by 1957.
23 Specific written and oral discovery will be needed in this case to prove with specificity these
24 allegations under 1957, against the above defendants; and during that process it is likely that new
25 names and additional DOE defendants will surface here in association with a variety of major
26 Olson, RAO and Skillings real estate transactions known to have occurred and also which have
27 been physically witnessed for many years very close to Remingtons residence, as well as all over
28

483
1 the southern Eureka, Cutten suburbs. During discovery, we will gather the appropriate information
2 in order to clearly identify and specify relevant enterprise related real estate in the FAC.
3 50. Gans 18 USC 1951, Hobbs Act violating extortion racket, defined, and explained
4 further as it is employed against Remington as the Enterprises major weapon. Gans has
5 established an extortive racketeering enterprise intended to destroy Remington and the Burl Tree
and to appropriate his land, while THEY all make lots of corrupt money, just as with any typical
6
type of organized crime family or organization. Here, Gans extortion racket has been trying for
7
years to provide Remington with protection from John Mathsons, et al, CRIMES against
8
Remingtons land, business and all property at that location.
9
Gans and his soldiers have clearly defined the threat for years, and made it much easier for
10 Remington to settle or totally give-up, however Remington never takes the easy way out, and is
11 a hard, serious fighter and worker38.
12 Gans clearly defined extortion racket confronts Remington daily and it is held over his
13 head continuously, wherein, IN SUMMARY:
14 1) Defendants have established an 8 1/2+-year reign of terror from the above-described
15 vandalism, burglary, daily FEAR of same, and from Gans believably executed mayhem, and
16 probable ORDER to commit serious physical violence against Remington, at some point soon.
17 The BASIC POINT HERE IS: Gans has repeatedly throughout 2016 made it crystal
clear that HE controls all of the lawless mayhem, destruction, vandalism and thefts of Burl
18
Tree property obviously perpetrated by Mathson and his fellow soldiers at 832 Westgate Dr.,
19
and GANS can STOP IT, anytime.
20
Its just as simple as that. The mayhem, destruction, horrors and continuous anxiety will
21
continue at Gans discretion until Remington has given given-up just contamination lawsuits
22 and fully surrendered to the Enterprises objectives, which incidentally, is never going to
23 happen until Remington is killed.
24 Therefore, as explained several times above, the 35-40 members of this enterprise and whether
25 they are eventually fined and imprisoned, hangs in the balance of Gans and his several
26 psychopathic soldiers. If the hit order to snuff-out Remington, is given to one of Gans 3-4
38
27 Remington has worked hard and often alone since age 8, and a 110/day heavy paper route, the
Washington Star, where Sunday papers weighing several pound EACH, and had to be delivered in
28 ice, snow, and bad weather by thin-tired bicycle for years.

484
soldiers whom, Remington now believes might be capable of doing such a violent act, then
1
everyone named in this statement and in these complaints will have a great deal to fear themselves.
2
Just as with the one ring that controls them all, here in an interdependent hierarchical RICO
3
enterprise, all members are ordinarily considered to be equally culpable. If one member commits a
4
violent act, it is then imputed to everyone in the enterprise, especially the named defendants in the
5 leadership positions, people like Brisso, Lawrence and Olson. They are presumed to be giving the
6 orders, were sharing in their conception, and in this case there is little doubt that they will be. They
7 will be knowledgeable about what the enterprise is planning, doing, has done and they will be just
8 as guilty as John Mathson or any other criminal involved here.
9 Mathson takes absolute orders from Gans, and whether Skillings does or not, or is FULLY
10 controllable by Gans, today, is not yet known or prove. If Remington was in this enterprise, hed
certainly want to find that out, as having Skillings being responsible for his being in or out of prison
11
would be unappealing;
12
13 2) Gans will gladly provide Remington protection and STOP Mathson, and his other
14 soldiers, IF Remington will give them Remingtons and the Burl Trees valuable estate, land,
15 inventory and business, that they seriously, permanently (at least that was their 1998 failed plan)
16 trespassed and encroached upon.
17 The Burl Trees ruined, encroached-upon land itself is now appreciating and worth at least
18 $120,000-180,000, however the more serious problem is the $300,000+ overall diminishment in
19 estate and land value, the $220,000+ and increasing BACK-RENT due, plus the related additional
20 costs, personal injuries and general damages, listed herein, related to the trespass and contamination
21 successive action lawsuits, and the other requested damages here.
22 3) The Burl Tree property has an annual water flow down Remington Creek of at
23 least 75,000,000 gallons of water per year, but appears to be on schedule to perhaps drastically
24 exceed that in 2016-17; but, however much it is in lost gallons, it is ALL now lost into Elk River
25 and the Ocean due to contamination and Remingtons inability to meet water ecoli and cleanliness
26 standards. That presently lost gallonage, at $6/1000 gallons is worth $450,000, with about $50,000
27 pumping, storage and overhead charges at the most. Remington could truck that water to Southern
28 Humboldt, or beyond or sell it locally, for little additional costs as independent contractor water
trucking charges are passed-on to the buyers.
485
1 THIS IS A MAJOR ADDITIONAL BURL TREE DAMAGE, $400,000 PER YEAR!!
2 4) Gans extortion demands also have OTHER contingencies, codicils, terms and
3 unacceptable provisions, including that:
4 A) Remington DROP his demands for back rents;
5 B) Remington drop all his present and future lawsuits; and,
6 C) Drop his legitimate and mandatory DEMANDS for full insurance indemnity against future
7 clean-up orders from the down stream land owners, The County, State, Water Board, National Park
8 Service and/or the EPA.
9 5) In exchange for that, i.e., Remington withdrawing or forgiving at least $1 million of
10 overall diverse kinds of damages of many varieties, Gans says and infers that THEY will also drop
11 their future threatened malicious prosecution suits, costs, expenses and attorney fee demands,
12 which are NOT a BIG fear, candidly. So, Remington gets protection from the Enterprises
13 racketeers plus they wont barrage Remington with a new round of frivolous lawsuits until he is
14 dead and his heirs get tired of fighting.
15 Not much of a deal for Remington, and therefore unacceptable. Hence, here we are.
16 Hopefully we will stay and remain in federal court, however if not, these RICO charges are fully
17 transferable to the state system, however inadequate, after appropriate statutory violation
18 modifications and edits.
19 Gans total possible future demands and most optimistic returns in his best case scenario is
20 possibly $50-60,000 (although difficult to get any kind of a total) dropped in exchange for
21 Remingtons obvious slam-dunk measurable, visible ACTUAL contamination on and beneath the
22 ground, plainly visible on ground penetration radar and metal detection type equipment, and his
23 resultant just due damages of a minimum of $300-500,000 to as much as $3-4,000,000, if a jury
24 ever actually considers and accepts Remingtons view of these cases, or TREBLE damages are
25 applied to some of them under RICO. Possibly the next jury will consider Remington as a
26 sympathetic figure and the true good guy here which he is.
27 Remington also has many other ways of demonstrating and proving what has actually been
28 dumped here by defendants, which include the 2006-2012 dump photographs for Mathsons
extensive spoliation of some of the debris partially exposed at the surface, plus Remington has
486
1 extensive records of his hundreds of hand-excavations all over the dump and what they revealed, as
2 he has duly sworn to for years, in scores of pages of declarations.
3 Remington alleges Gans, RAO and defendants additionally violated 18 USC 1511, wherein
4 they risked prison for years with a gambling operation, meeting all definitions in that law. They
5 buried hazardous treasure, to them and it could be valued by what was paid them to get rid of it,
6 in the beginning, around 1998-2000, gambling that no one would discover it, but if they did that no
7 one could force to have it removed. So far, Olsons, Mathsons, Lawrences, Brissos and Gans
8 gamble has paid off big time! They have all hit the State regulatory casino jackpot super big, to
9 date, for more than $1 million of tax-free profits unknown to almost anyone except for
10 Remington and the RICO membership.
11 Now they are ALL still gambling that Remington will not be able to execute its removal, even
12 after its discovery, which is what these cases are now about. Defendants are still winning here
13 today, winning big, and they still hold an unbeatable house edge over the long term, however if
14 this RICO suit gets in the San Francisco federal court and stays there, the house cannot last for
15 long!
16 So far, RAO, Gans, Allied and Mathson are up at least a million dollars or possibly even 2-4
17 times more then that on their gamble, as though this were an Indian casino. However, ALLIED
18 INSURANCE and all of the RICO defendants, now continue to roll the dice and play their poker
19 hands or slot machines WITH that million dollars to attempt to double it or maybe LOSE IT ALL.
20 Well see. Maybe other alternatives will emerge in this Court if these cases are accepted here.
21 SIMPLY SUMMARIZED: DEFENDANTS EXTORTION RACKET FEARFULLY
22 THREATENS REMINGTON WITH the rather simple ultimatum: You drop your lawsuits, rent,
23 back rent, miscellaneous general and special damages, stigma, future indemnity and all cash
24 remediation demands, and WE WILL STOP OUR CONTINUOUS ALMOST DAILY COSTLY,
25 ANXIETY CAUSING criminal acts of vandalism (costing Remington well-over $100,000 alone, to
26 date); and also drop our cost, fee, punitive damages, slander, abuse of process, vexatious litigant
27 and malicious prosecution demands and/or likely future lawsuits.
28

487
1 Gans RICO ultimatum continues: Generally, WE (defendants) get all Remingtons land
2 North of the creek FREE, plus most of the value of the entire estate south of the Creek also, and
3 you take nothing, and leave the area in shame and ignominy.
4 OTHERWISE, there will be hell to pay and theres no telling what Mathson, Randall,
5 Kishpaugh and Skillings, et al may do if unleashed from Gans so-far semi-civilized, non-
6 violent corrupt control.
Pursuant to Mendoza v. Zirkle, 301 F 3d 1163 (9th Cir 2002), as quoted in Diaz, 420 F 3d 897,
7
at 4, The 9th Circuit in 2002 recognized a new business interest property loss relevant HERE:
8
The legal entitlement to business relations unhampered by schemes prohibited by the RICO
9
predicate statutes, (at case # 5). That even applies to Remington and the Burl Tree. Today,
10
Remingtons legitimate business activities are all gravely restricted, seriously damaged and
11 endangered, deteriorating or totally blocked by the RICO enterprise, as described.
12
END OF 101-PAGE CHRONOLOGICAL (SUMMARY OF) PATTERN OF
13
PREDICATE ACTS, 2012-16, DATES AND BACKGROUND.
14
[Dated: November 2016 and partially superseded, added-to and revised through March, 2017]
15
16 5 (c) This RICO claim is NOT based-upon the predicate acts of wire & mail fraud.
17 However, numerous mail and wire fraud are alleged here, and the circumstances constituting
18 said frauds have already been identified with sufficient particularity under Federal Rule of Civil
19 Procedure 9 (b). The time, place contents of the alleged misrepresentations or omissions and the
20 identity of the persons to whom and by whom the alleged misrepresentations or omissions were
made have been listed in complete detail above. Defendants know what is being alleged, are very
21
well-aware of what federal and state laws they have violated, and they can pull-out the documents
22
themselves, study them and then reply and defend themselves against these allegations, also with
23
the proper specificity required under federal law. At future stages in this process such as at the
24
dismissal stage and in the FAC, Remington will gladly provide additional details as needed of the
25 fraud cited plus the others that have been omitted to date in the interests of a semblance of
26 brevity.
27 Considerable discovery is now needed in these cases, specifically regarding all of the
28 complex communications between the RICO enterprise members. Additionally, these cases have
been going-on for nearly 10-years now and Remington intends to review the tens of thousands of
488
pages of illicit and often offensive documents including fraudulent declarations and summary
1
judgment claims by Gans in four different summary judgment motions, since 2011.
2
Remington therefore intends to add another 10-30+ obvious mail frauds and emails as related
3
to those defendants numerous motion documents, as time permits their review. Therefore, as and
4
when needed we will augment and supplement the mail and wire frauds, and probably discover and
5 ADD additional kinds of violated state and federal predicate acts in future offensive documents, and
6 in the reply and opposition to defendants inevitable motion to dismiss.
7
5 (d) Describe whether the alleged predicate acts relate to the enterprise
8
as part of a common plan. ABSOLUTELY, they DO.
9
If so, describe in detail. Gans RICO Enterprises predicate acts absolutely related 100% to
10
the Enterprises known stated, actively pursued goals and purposes as evidenced by their behavior
11
for many years. Those clear-cut goals and obvious objectives were clearly and specifically set forth
12
above, and elsewhere and additional in different aspects of said objectives are also considered
13
further below.
14
Why was Gans enterprise needed and created in the first place? As explained throughout this
15
statement and complaint, Gans gradually developed this enterprise as his methods became
16
increasingly corrupt and criminal, which was necessary because what began as relatively ordinary
17
conventional and semi-ethical legal defense and motion processes back in 2008 and continuing with
18
increasing corruption into 2011, simply ultimately failed to accomplish Gans objectives and goals.
19
In other words, Gans began all of this is a simple and ordinary contamination defense and
20
retaliatory preemptive frivolous lawsuit to try to scare Remington away, but when none of his
21
honest, highly aggressive but normal, garden-variety ethical legal tactics worked he progressively
22
became increasingly corrupt and criminal, to reach where we sadly are today.
23
Increasingly, after 2012-14, Gans and his associates were forced into increasingly criminal
24
activities in order to have any hope of winning these cases. Winning at all costs no matter what extra-
25
legal corruption was required was Gans, Mathsons and RAOs sole purpose from the beginning.
26
Gans just wants to win too badly and is willing to abandon all ethics and morality to do so.
27
Apparently he was brought up as a child to learn that cheating, stealing and criminal activity is all
28
right as long as you win. Perhaps in sports, the mantra of winning is everything applies, but in the

489
1 law, if winning is not done by legal means then prison could and should often be the resulting
2 penalty. Therefore, during the last four (4) years the enterprise has employed increasingly illegal
3 methods to the point where by 2016 they employ nearly 100% fraudulent, deceptive, deceitful,
4 unethical and/or clear-cut felonious means in violation of all of the state and federal laws cited
5 herein with those cited penalties, fines and imprisonment for their violation.
6 Gans RICO enterprise does nothing here unless it directly relates to accomplishing those
7 crucial purposes which succinctly can be summarized as:
8 1) Saving money for the enterprise by avoiding all cleanup costs;
9 2) Stealing Remingtons encroached-upon land free with no purchase or rental fees, and
10 presumably ultimately purchasing his entire damaged estate for pennies on the dollar;
11 3) Making large sums of money for Gans and all other enterprise members and experts involved in
12 these cases;
13 4) Crushing Remington financially and emotionally indefinitely with the objective of forcing him
14 to pay all enterprise and Allieds expenses eventually;
15 5) Covering-up the enterprises crimes while importantly staying-out of prison;
16 6) Additionally, punish and torture Remington even further and make him pay for his arrogant
17 audacity at attempting to stand-up for justice against this powerful enterprise, and eventually to
18 drive him from this area completely, whether alive or dead.
19 7) Perhaps above all, Gans has intentionally succeeded in destroying all of the joy of living and
20 working in his gardens and in this neighborhood for Remington.
21 Remington now experiences a feeling of dread, tension, anxiety and possibly impending
22 doom whenever he comes to his offices and estate every day for 8 to 10 hours.
23 Similarly, working outside, always within sight of Mathsons ugly fences and sterile land,
24 Remington can never relax now and never let his guard down completely because, as fully
25 described above, Mathson watches continuously from his secure, well-concealed game blinds
26 with a telephoto camera lens constantly aimed in search of Remington, and some day that might be
27 replaced with a rifle telescopic sight. How will we know when that day comes, except from the loud
28 cracking sound of several rifle shells being fired, with instant pain or possibly instant death if
Mathson or Skillings know how to shoot straight, which is highly doubtful.
490
1 In summary, Remingtons former idealistic, very happy carefree retirement gardening has
2 been deeply impacted, substantially ruined and completely decimated for months, growing into
3 years, at a time. Maybe its just Remingtons imagination, but inferentially as he has stopped
4 working continuously and tirelessly on his estate development, most of the neighbors across the
5 street and nearby seem to have also lost some of their fire and enthusiasm almost in sympathy with
6 Remingtons plight here. In other words, no one within view of Remingtons property has done any
7 noticeable or significant development, since about the time that these lawsuits and all Mathsons
8 harassment, complaints and criminal destructive activity began here around 2007. Whether there is
9 actually some adjacent emotional depression or other influences on some of these adjacent
10 neighbors, or whether thats just imaginary or not, we will know better when these cases are over
11 and Remington finishes off his estate as the center and focal point for this entire area. When that
12 happens, Remington would expect several dozen of the nearest and adjacent neighbors to also begin
13 working on their properties again to try and improve them and bring them up to a higher standard
14 more compatible with their adjacent land uses.
15 The following discussion will explain further how the above-cited defendants and predicate
16 acts were specifically tied-in to the Enterprises obvious objectives and purposes. Although perhaps
17 partially repetitive, due to the several months time that this document took in its drafting, it
18 nevertheless adds some new detail and specificity regarding exactly what the enterprise has done, is
19 still attempting to do and how it has continued to damage Remington and the Burl Tree, and
20 continues to threaten the destruction of both in 2017.
21 1) Save money for the insurers, RAO and Mathson by avoiding all cleanup costs here on
22 both properties forever, or until Remington dies. Consider a small portion of the history of these
23 lawsuits:
24 A. Numerous mediations, settlement proposals and settlement negotiations have been
25 undertaken here since 2007 and at least two settlements were fully reached and/or shook-on in
26 principle, one in October 2007 and another in August 2011. both settlements were immediately
27 revoked by Gans, within about a month in 2007 and within two days in August 2011,when agreement
28 was very close, but then the technical federal summary judgment made Gans greedy and in reach of
his ultimate objective of crushing Remington completely, so his true character, motivations and
491
1 objectives were clearly revealed at that time. At least eight other Remington settlement proposals
2 have been ignored over the years without any response, comments or counteroffer.
3 Gans, and now his enterprise also, are getting rich off of these Remington litigations and
4 clearly defendants have never wanted to settle this while Gans is gaining such valuable litigation
5 experience and getting paid hundreds of thousands of dollars plus all his expenses by Allied
6 Insurance and specifically by Linda Lawrence. Gans has now based his entire career, 100% of his
7 credibility and now his very FREEDOM, upon winning all these cases BIG, but now his actions
8 have degenerated into senseless and unsustainable malicious criminality, as though he were a
9 crazed party zealot here, where now he must win these lawsuits no matter what unethical or
10 criminal acts that takes, which explains further the gradual creation of and evolution of the
11 activities of his RICO enterprise.
12 B. Never have defendants even once ever shown any interest in discussing a site remediation
13 here. For example, in a 2010 mediation with Linda Lawrence present, Gans chief environmental
14 expert Ferriman had recently boasted that he could easily remediate Remingtons land in 3-4 days
15 with a long reach excavator from Mathsons land for under $11,000.
16 But, when Remington immediately accepted that proposal to end all this back in 2010,
17 because that was substantially the only then known material issue remaining at that early stage, and
18 was before the discovery of massive hydrocarbon, asbestos, bacterial, etc. contaminations,
19 defendants and Gans immediately withdrew that proposal, citing new technicalities and added that
20 Mathson did not want any truck tracks crossing his lawn, and related trivia and frivolities, leading
21 us to where we are today.
22 C. Remington has now twice begun remediation on his own here and each time defendants
23 blocked it as previously described, first in December 2012 and into 2013, in the Figas extortion
24 incidents, and then again in November 2015, when Wayne Marsh was also harassed, threatened,
25 intimidated and extorted to absolutely stay-away from what RAO buried over here on their dump,
26 which now substantially occupies Remingtons land.
27 For the last several years and especially since the creation of this racketeering enterprise,
28 Defendants have proven that they gravely fear any excavations occurring at the dumpsites,
which very strongly infers that they are deathly afraid of the dire secrets which they buried there.
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1 Probably, only Olson and Skillings truly know know all of the toxic secrets about exactly what is
2 buried where. They are absolutely unwilling to have their contaminated wastes, which they buried
3 on Remingtons land, excavated, revealed and removed, and so far have been willing to resort to as
4 much criminal extortion and threats as necessary to preserve their secrets. Three (3) times now,
5 including the above 2010 Ferriman remediation attempt, Gans and RAOs extortion and threats of
6 arson or other severe property or personal injury damages have succeeded. Each time now,
7 whenever discovery of the RAO-Mathson dark secrets has been threatened with being imminently
8 revealed within minutes or hours, the enterprise has always taken drastic measures against
9 anyone who proposes to reveal the hazardous wastes, or possibly the much worse horrors that
10 are apparently buried there. TWICE now Skillings, Olson and Gans have totally panicked when a
11 contractor with an excavator on Remingtons property, even 200-300 feet away, threatened to may
12 be go further, and maybe attempt to make a difficult road into the hazardous waste dump.
13 Remington is not yet certain what defendants buried there, but something has been
14 uncovered over there recently which has severely interfered with his health and has nearly killed
15 him with infections, immune system-attacking pathogens or bacteria, plus the rampant microscopic
16 chrysotile and other windblown asbestos particles, which cause uncontrollable coughing from 100-
17 feet away from the dump. Defendants dumped hazardous wastes on Remingtons land, which are 8-
18 20 feet deep in places there, and Remington now assumes that it will be seriously criminally,
19 incriminating hazardous material which they buried and concealed here, which defendants have
20 shown such a propensity to panic over and to commit violence over in order to prevent anyone
21 from doing any digging investigations even anywhere near the dump! Eventually well do it, but not
22 this winter of 2016-17 now.
23 D. Gans has further pursued the enterprises objectives, goals and purposes for many years by
24 attempting to refute, belittle, eliminate, deprecate, and/or incriminate all of Remingtons testing and
25 environmental experts. Additionally, Gans constantly accuses Remington of evidence tampering,
26 spiking his land and Mathsons deliberately himself with hydrocarbons; apparently accuses his
27 SHN experts of the same, especially John Aveggio, who is now dead and cannot defend himself;
28 and has specifically accused our experts of falsifying, doctoring and/or producing incompetent
testing result 2009 and 2011, then followed-up those wild, frivolous and unfounded allegations with
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1 additional unpleasantness after his death, and then rubbed further salt in the wound by
2 eliminating his able replacement Mike Foget, also from SHN, but unfortunately also under Jeff
3 Nelson, a named enterprise defendant here, who has as alleged above been improperly influenced,
4 prejudiced, extorted, bribed, or possibly worse here, according to certain facts we intend to
5 discover. Present inferences are that the Gans-Ferriman lower-level tester networks alluded to
6 elsewhere herein were instrumental in causing Nelsons SHN contract breach involving Foget.
7 Today, all SHNs tests, documents and sworn statements are in doubt and being contested by
8 Gans enterprise because they conclusively established that defendants soil encroachments with
9 hazardous substances can be easily removed as prescribed under Aveggios RAP plan completed in
10 June 2011. The water contamination which was more fully delineated later in 2011 would require
11 additional measures.
12 E. Even Remingtons new replacement Dr. McEdwards is being contested and ridiculed based on
13 cynical, bad-faith partial questioning and then improper coaxing of the court to only allow
14 McEdwards to testify about the few very incomplete topics which Gans intentionally questioned
15 him on in February 2016. Despite Remington saying repeatedly in the deposition that McEdwards
16 would be testifying at trial about everything that Aveggio had been prepared to discuss, Gans
17 ignored that when railing and complaining in writing to the court. Said court now appears to be
18 prepared to restrict his testimony according to Gans fraudulent statements about the deposition and
19 may not even look at the deposition transcript itself to see who is telling the truth Remington or
20 Gans. That is because, the courts former law partners inexplicably still have at least 10 times the
21 initial credibility of Remington on any given case issue, and although Remington is almost always
22 right and truthful, and Gans is the opposite, and that disturbing and grossly unfair fact still
23 presents a nearly impossible obstacle for Remington to overcome when debating these hundreds of
24 salient case issues, which have almost all been explained herein. Additionally, and unfairly Gans
25 has repeatedly tried to influence the court to bar all of Aveggios testimony from the next trial, no
26 matter who presents it, which is obviously grossly unfair, since as discussed above, said court
27 refused to allow Dr. McEdwards to do any of his own testing, but rather must solely rely on the
28 testing that Aveggio did. Therefore, if Gans succeeds in barring all of Aveggios work from the next

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1 trial as he has been attempting, then quickly and inevitably Remington will wind-up with no
2 environmental expert testing at all, and his case would be automatically defaulted accordingly39.
3 F. Gans fully executed plan since 2010, in dozens of motions and documents has been to attempt
4 to refute Remingtons tests and proofs of contaminated land by: falsely and un-reliably testing on
5 Mathsons land and thereby fraudulently proving that Mathsons land is pristine and
6 uncontaminated and then arguing that because all Remingtons contamination came from Mathsons
7 pristine land, therefore Remingtons land is also pristine, despite our lying eyes and obviously
8 spiked test results, which said results actually DO prove that Remingtons land is contaminated
9 with dozens of carcinogens and the related lethal materials as cited.
10 G. Gans also has frivolously and fraudulently deprecated Remingtons test results from Stevens
11 Ecology and the University of Massachusetts all perfectly accurate and ALL absolutely properly
12 and professionally scientifically sampled tests, however currently Judge Reinholtsen seems inclined
13 to bar them all as incompetent, despite not yet examining Remingtons sampling expertise as
14 intended and promised.
15 Now, after evocation of collateral estoppel, none of Remingtons hydrocarbon, E. coli or
16 metals test in soil or water appear to be admissible under Judge Reinholtsens draconian granting of
17 MIL #20, a grave error that Remington believes will be easily overturned once it is properly
18 understood, either on appeal in state court or preferably here.
19
20
39
See also the collateral estoppel section of this complaint for a discussion on the injustice and
21
illogicalness of applying the federal courts ruling pertinent to denying five statutory claims because
22 Remington had no expert to sustain them to the state court case where that same expert was fully in
the case and had fully refuted each and every allegation and argument which Gans made
23 successfully in federal court. The only reason Gans was granted summary judgment there was
24 because Aveggio was NOT disclosed into the case, under Rule 26. Conversely, with Aveggio in the
state case it is logical that he would have easily WON or at least very HIGHLY contested it. In no
25 event or stretch of logic, does removal of Aveggio lead to the conclusion that the dumpsites were
not contaminated when Aveggio swore for years that they were contaminated! Judge Reinholtsens
26 application of collateral estoppel from a federal case where summary judgment was only granted
27 because there was no environmental expert in rebuttal to an almost identical case where that expert
was in the case is just illogical. It is hard to explain clearly, but what is going-on now is complete
28 nonsense and is unjust, but may take wiser judges here, or in state appellate court to sort-through
clearly, unravel, explain, and properly substantiate with appellate case law to undo this present
injustice.
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1 2) Appropriate, steal, keep and effectively get all of Remington's land free during this
2 process, including the substantial portion they have directly trespassed and encroached upon, USE
3 NOW as though they own it, and have used continuously and depended upon entirely and
4 completely for the last 19-years in order to provide crucial lateral support for their entire yard,
5 including all of their lawn buildings, trailer home and conventional residential structures.
6 Defendants should have purchased or alternatively rented that crucial land which they
7 essentially built-on, used as a quasi-retaining wall and now rely on as the foundation for their entire
8 property. Forcing defendants to pay for that long time use of Remingtons important, crucial, fertile,
9 redwood-forested land is one of Remingtons top priorities as a recoverable damage in these
10 lawsuits.
11 Defendants additionally contaminated and severely damaged an additional large area of land
12 below the dump areas and below the land which they directly occupy in the dump areas. That
13 additional Remingtons land has been harmed and continues to be damaged from hydrocarbon and
14 sewage contamination, plus the continuous rampant slides, caused by the incredible ferocious
15 runoff from their twin 6-inch pipes during any heavy rain, which are described and complained of
16 elsewhere. All of those contamination and complex, continuing slide damages have been explained
17 in detail in the environmental damages portion of this lawsuit.
18 Cumulatively, defendants should have bought that impacted and ruined land or have paid rent
19 for it for the last 18+ years. At $1000 per month that background alone totals more than $220,000,
20 and rising, whereas just purchasing that impacted land outright would probably cost about the same,
21 which possible alternative was rejected many years ago because Mathson does not want any more
22 contaminated land either, to reduce the value of his estate below the approximately zero dollar
23 value it has today. Regardless of all that, Gans Enterprise, like a mafia family, has calculated that
24 they make out MUCH better financially if they just use that land free and do not buy it or rent it.
25 Accordingly, that land issue and getting it all free by stealing it, is among the enterprises foremost
26 objectives.
27 Perhaps repetitively and by way of another summary, the Mathsons have appropriated and
28 now occupy permanently at least 1/3 acre of Remingtons prime fertile garden and redwood forest
land with their 600-1000 cubic yards of hazardous debris which includes some of the affected land
496
1 below all of that debris. As explained, below the main dump itself numerous solid and liquid toxins
2 continue to exude and flow in various types of above ground then subterranean watercourses
3 coming-off of Mathsons hill, and considerable erosion and slides are caused by Mathsons runoff
4 and dumped debris which damage Remingtons property, as explained and have been complained
5 about for years.
6 Never have defendants offered to compensate Remington for that intensive use by buying or
7 renting it and then effectively fencing it off from Remingtons pristine property. Many years ago,
8 Remington offered to trade his contaminated land to Mathson and for equivalent unadulterated and
9 pristine adjacent land, which land had already been inadvertently fenced-in. Informally, in 2007
10 John Mathson and Bruce Remington did reach a handshake agreement involving that general
11 concept, which Gans immediately sabotaged when he heard about it, perhaps understanding that
12 Mathsons land would be depreciated by the several hundred thousand dollars which Remingtons
13 land has been depreciated by that contaminated mess. Gans personally has made corrupt wage
14 profits of at least $300,000 during the period since then, so apparently was prescient as to how to
15 benefit himself in any case, which rather clearly has been his only concern. As explained, that fact
16 was plainly forecast by the original Mathsons surveyor, Hubbard, who was the original one to say
17 a full nine years ago that: The only ones who would benefit from litigation over these property lines
18 or dumped debris would be the attorneys, and then he almost begged John Mathson to pay attention
19 and listen to him. Remington agreed with Hubbard and also urged Mathson to listen, but by that
20 time he was angry and refused and was fully under Gans corrupt influence and spell, and is never
21 looked back since then. In 100 years, when the history of this case is written or explained by
22 someone, Hubbard will probably be remembered as the only wise one, the only adult in the room,
23 and had he been listened to the world would be a much better place today, and quite possibly the
24 prisons would have a few less inhabitants.
25 As above, also in various mediation and settlement attempts Remington also offered that
26 contaminated land, variously in trade or for sale or rent, which Mathson and RAO had encroached
27 upon since 1998, but Gans, Mathson and defendants have rejected all reasonable offers to buy trade
28 or otherwise resolve this suit.

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1 The fair market sale purchase value of that entire impacted upper and lower 1/3 acre which
2 supports the Mathsons entire developed area above and involves his gardens, lawns, sheds, main
3 house and huge garage would be at least $150,000 or more. However, Remington has offered it to
4 defendants for $1000 per month or $12,000/year as a rental, but they have not responded.
5 On that basis, back rent of about $228,000 will be owed for the use of Remingtons land by the
6 time this RICO cause of action is being considered during 2017 by the relevant participants. That
7 some has been requested repeatedly and is demanded once more here. Coupled with the enterprises
8 first objective of avoiding all clean-up costs, this objective number two avoiding all rents and
9 compensation to Remington for their use of his lands is also perfectly consistent with their corrupt
10 purposes, unfair business practices and other complained of plans, purposes and actual ongoing
11 criminal actions.
12 3) Make huge sums of money for Gans, Allied, RAO and Mathson, by billing thousands of
13 fully documented, high-priced hours to Allied, plus Maximize all family enterprise members
14 wealth, income and happiness, starting with Gans, of course and the $300,000+ he has made so
15 far to date from these cases, and then the highly-paid Lawrence, on down to their numerous experts,
16 clerical workers and lying family percipient witnesses, all of whom are happy, well-fed, care-free
17 and making much more money here than they normally would in their regular lives. To accomplish
18 all that, like the big happy crime family that they are, the racketeering leadership needs to keep all
19 members and soldiers happy, prosperous and eager to keep participating, preferably on an
20 escalating scale of increasing production and creativity on behalf of all levels of the enterprise.
21 A. Everyone in Gans RICO enterprise is making fantastic money here so far and that even
22 includes Allied insurance who apparently are paying all the bills here at the moment, but theyre
23 also saving possibly $400,000, or a lot more that it will eventually, potentially be paying out here.
24 $400,000 invested in this runaway stock market and other real estate and cash producing
25 investments is about enough to pay most of their bills probably. Therefore, if the RICO enterprise
26 can defeat Remington and accomplish all of their goals above, then even Allied could conceivably
27 wind-up with a financial profit here, but if not the other 35-40 present members of this criminal
28 enterprise will all be making great money, and probably without exception more money than they
could make doing anything else right now, in some cases 5-10 times more money. Gans, Lawrence
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1 and some of Mathsons friends, drinking and drug buddies probably head the list for income from
2 the RICO family enterprise versus what they are really worth in the marketplace.
3 B. The Mitchell attorneys are getting wealthy here. Additionally, and specifically as best we
4 can estimate today prior to detailed discovery:
5 1. Gans hourly pay rates have been previously proven, and provided, and his REAL rate of
6 pay since 2007, and not his wannabe Lodestar rate, based on excellent big city attorneys pay rates,
7 IS possible to estimate reasonably accurately, some of his pay rates and have also done local
8 attorney salary surveys previously. 8-10 years ago he was paid a proximately $85 per hour to
9 possibly up to as high as his present rate would be estimated, which is about $130-150 per hour.
10 Those rates are based on many factors including an attorney wage and salarys survey Remington
11 did in 2009+ Remingtons knowledge of what Harvey is being paid by an insurance company to do
12 relatively high level trial litigation. However, insurance companies appear to easily be able to beat-
13 down mediocre-average attorneys to the $130 per hour range without much difficulty. Plotz is still
14 in the novice, inexperienced and almost worthless category, but would be estimated to make about
15 85-$90 per hour nevertheless which would be a lot more than 90% of the other RICO enterprise
16 family members. The Mitchell firms starting pay for an inexperienced attorney right out of law
17 school was pretty well-established back around 2009 by a salary survey.
18 Without knowing exactly how many hours Gans actually billed to Allied, but fully
19 understanding that he has put in many thousands of hours into these cases, probably only about half
20 actually billed, it is reasonable to estimate that Gans has made more than $300,000 to date from the
21 Remington matter and perhaps a lot more. Remington, on the other hand, has put in two-three
22 times more hours than Gans undoubtably, but he is older, believes in providing 10 times more
23 detail, and evidently thinks and works slower also. Of course Remingtons work is honest, better
24 researched and written, but excessively redundant, and a lot of it is inefficient and never fully
25 implemented properly in practice, at least yet.
26 2. Brisso put in many hours back in 2008-9 and some since then, however probably most of his
27 time today is not billed, as an act of charity to Plotz whose entire billing, for about two years, would
28 usually have been based on the Remington cases. If so, hopefully hes made nothing over the last 5-
6 months here, but maybe they found another case that hes qualified to handle, as there has been
499
1 little direct litigation activity involving the Mitchell firm anyway since August 2016, but that will
2 be changing now. Between Brisso and Plotz, alone, Allied must have wasted almost $60,000 on that
3 bunch to date, with not much to show for it that Remington can see. In any case, like a common
4 street gang, all of the attorneys certainly and other RICO members here are all living very
5 comfortably and happily, never miss a paycheck or a meal, and could and presumably do, easily get
6 pay raises at any time, by padding a few more hours.
7 3. Gans has a lot of experts for his enterprise. Most areas of interest are covered at least twice.
8 For example, they had one perfectly good survey then paid another $7-8000 bucks or more for
9 Pulley to do another survey, just because he agreed to follow Gans disingenuous orders and focus
10 on crushing Remington, whereas Mark Hubbard did not, and refused to prostitute himself. Hubbard
11 was an ordinary honest expert and he cooperated with Remington, early on, and made every attempt
12 to resolve the litigation, and was not in favor of crushing and humiliating Remington and making
13 him pay all expenses for the litigation and also cleaning up his own property. He is the one that said
14 to a very angry John Mathson: You really should try to settle this thing because if it goes to court
15 only the lawyers will benefit. No truer statement has yet been made in this lawsuit.
16 Counting all the money defendants wasted on their surveyors and wasted even more on their
17 massively expensive environmental testing experts, Remington would estimate that theyve spent
18 certainly over $50,000 on their experts, alone and so far only Pulley has been to the trial, so
19 theyre on track for more than $100,000 total, certainly. Big waste of money. Its a pity that wiser
20 heads did not take over this litigation a lot sooner, but it is now way too late. All defendants have
21 now are: big bullheaded egos only concerned with winning by any criminal means necessary,
22 but now they have a much bigger problem which is to seriously begin covering-up what theyve
23 been doing to avoid prison.
24 4. The RICO enterprises other perjuring witnesses. All are in effect lying, to some
25 significant extent, salaried and/or bribed and there are many of them out there, just in the
26 contamination cases alone. The RICO case has a lot more high paid perjurers, who just happen to
27 strangely all be on the defendants side. Remington would estimate that the enterprise has so far
28 spent in the area of $10,000, just on their non-expert percipient witnesses and mostly oriented
towards the recent SOL trial.
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1 Obviously, defendants will eventually be spending a huge amount in this area and certainly
2 well over $100,000 before this is over. And, when its over there may well be fines to pay on top
3 of everything else. Those fines will be presumably payable by the incriminated individuals
4 themselves, Hypothetically people like Lawrence, Gans, Brisso, Plotz, Mathson, Randall and
5 Nelson, just to name a few obvious ones, and in any case will not all be supported by Pappa-
6 Allied.
7 At the moment, not one known member of the enterprise seems to have much motivation for
8 ending these lawsuits, which guarantees that they will continue indefinitely, or at least until
9 Remington can spark some interest on the part of the criminal authorities, hopefully while he is still
10 healthy.
11 4) CRUSH Remington financially, emotionally, psychologically and intellectually by
12 forcing him to pay all expenses in these never-ending litigations including: ALL cleanup costs,
13 all expert costs from both sides and all defendants costs and attorney fees by means of obstructing
14 justice, bribery as needed, intimidating and extorting as many witnesses as required, under color of
15 law since Gans still surprisingly remains a legitimate and licensed California attorney.
16 As explained throughout these documents, the enterprise now wants a total victory in these
17 cases, and that means more than just a financial win, but now they want to beat-up Remington
18 totally. The Mathsons and Gans especially want to beat all the arrogance, cockiness and usurpance
19 of their authority out of Remington because of his inconceivable opposition to the mighty Mitchell
20 firm. Several years ago it also became apparent that breaking Remingtons health would also help
21 them break him financially and make him physically unable to continue to prosecute these lawsuits.
22 Also, if they just killed him that would also make it a lot easier for them.
23 5) Cover-up and also minimize all the crimes by all defendants family members here since
24 1998, in order to mainly STAY OUT OF PRISON, and enact or put into effect #1) above (save
25 money and avoid cleanup costs) and the rest of their objectives. Total cleanup costs here on both
26 properties would be over $500,000, which defendants have refused to pay, and in order to avoid
27 that, and to avoid carrying- out their legal responsibility to clean-up the mess that they made here,
28 defendants have been willing to violate any and all laws as needed especially beginning in the
2012-16 period, when this RICO enterprise was created. These lawsuits only seek the limited
501
1 cleanup of Remingtons impacted land which presently has been bid at about $200,000 for the soils
2 and at least another $50,000 for setting-up additional water treatment options, with some sort of
3 additional annual electrical charges thereafter. What defendants ultimately do about their own
4 property is not in Remingtons hands but eventually will be determined by the Waterboard and new
5 management at the Health Department who have not yet been bribed or otherwise improperly
6 influenced by Brisso and their enterprise. Removing the large amount of hazardous wastes under
7 Mathsons lawns is now estimated to cost another $250,000, because its a much larger volume than
8 what is on Remingtons land, but it is a lot easier to reach, excavate and load. It is also generally
9 believed to be less toxic than what was sorted and buried on Remingtons land, except for the super-
10 hazardous wastes believed to have been buried in Mathsons major draw protected by the twin 6-
11 inch pipes. What defendants buried there is believed to be at least rusted-out leaking 55-gallon
12 drums of hydrocarbon contaminated soils, based on the highly hydrocarbon contaminated waters
13 exuding from beneath that area, to as bad as biological or radioactive hospital wastes. However
14 right now we just dont know for sure what is there, but it should be removed in spite of the fact
15 that it would tear-up Mathsons lawns, but so what, they can regrade and re-seed?
16 As written herein and throughout the state litigations, what eventually happens to Mathsons
17 property and the contamination that is buried there is not Remingtons direct concern. He does not
18 like it, but these lawsuits do not involve that at the moment. Contaminated water flowing down off
19 the hill from Mathsons property will be captured and treated under our remediation plans, as
20 proposed herein.
21 This cover-up by defendants has become entirely corrupt since they, without limitation have:
22 had to spoil evidence by removing all visible debris; they have had to grossly understate all
23 significant parameters of volume and toxicity (see below) regarding their dumped debris; and they
24 have had to bribe and/or extort numerous experts and percipient witnesses, with no end in sight,
25 beginning as early as Paul Dalka of the county when this project was first initiated around 1998.
26 Later the RICO defendants severely intimidated, extorted and/or blackmailed or bribed Bob
27 Figas in 2012-13 and then Wayne Marsh to keep them from excavating anywhere near defendants
28 criminal dump. Probably only Skillings and Olson know what their full criminal exposure is which
was apparently serious enough to take a very heavy hand to Figas and then Remington and what
502
1 can only be construed now as a desperate and final attempt to protect their very serious and
2 incriminating secrets. Like a band of pirates guarding their shallowly buried treasure and burial
3 ground for their adversaries killed in battle, inferentially defendants will now protect that dump at
4 all costs including destroying, extorting, vandalizing and murdering anyone or anything is needed,
5 to keep themselves out of prison, where it now appears that several of them belong.
6 a. Gans fraudulently has bribed his experts to falsely swear that defendants contamination
7 of Remingtons land was di minimus.
8 Specifically, as explained further below, Gans and his entire enterprise have systematically
9 and fraudulently attempted to minimize and reduce defendants environmental crimes to absurdity,
10 as mostly explained in the environmental portion of this lawsuit, but in summary involved: Gwinns
11 intentional misinterpretation of our boring data DEPTHS, and intentionally ignoring our bit
12 refusal results was perhaps their most significant intentional fraudulent deception. Gwinn then
13 knowingly and fraudulently declared the entire volume of fill on Remingtons land as being less
14 than 80 cubic yards, whereas, our experts detailed estimates were well-over 500 yards and quite
15 probably 1000 yards40. Remington is the most competent mathematical and physics expert on our
16 side, and very arguably from either side, as fully documented elsewhere (with more than 30 Ivy
17 League engineering college credit hours of calculus, differential equations and above) and he made
18 a very detailed series of volumetric mathematics calculations using three different methods in 2011.
19 At that time, the most accurate calculus-based solid geometrical estimate was 560 cubic yards.
20 However, over many more years, new estimates in 2015, based on additional depth
21 measurements at trees in the dump that were buried up to 15-feet deep up their trunks initially, plus
22 one new drilled depth boring, again until bit refusal at about 5 feet deep, steeply downhill from
23 one tree, now indicate that 1000 cubic yards of defendants encroaching fill volume is also highly
24 . Gwinn Swore that he used our SHN borings to calculate his understated version of the volume of the
40
25 fill. Gwinn used average depth measurements of about 12-18 inches because no SHN borings got deeper
than that. However, it was well known by everyone that no SHN boring reached native soils because every
26 single one of them hit giant concrete or asphalt debris so the holes had to be aborted. Whereas, when
Gwinn made the knowingly fraudulent assumption that every SHN boring went all the way through the fill
27 and therefore determined its depth, those fraudulent calculations were absurd because the fill was
approximately 6-15 feet deep in those same areas, according to our complex calculations and excavated
28 depth measurements, and therefore Gwinns entire volume calculation was wrong by a factor of 4-6 just in
the depth parameter alone! He also understated the area by 100 to 200% causing an overall multiplicative
error of 600-1000%, as explained elsewhere.
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1 possible41. As our new expert Dr. McEdwards says, we wont know for sure until we remove it and
2 count the loads, nor is it that important to know exactly how much is there now. The only thing that
3 is obvious today is that theres a huge amount there, millions of pounds of hazardous wastes, which
4 are contaminating the environment and the creek and all need to be removed.
5 b. Gans Enterprises experts have falsely sworn to gross understatements of the volume and
6 toxicity of the encroaching fill.
7 Generally on that topic, Gans has systematically used his 7-8 experts (including Pulley as
8 discussed above) plus 4-5 attorneys to consistently fraudulently understate the volume of their
9 gigantic encroachment in 1998, and to understate its toxicity and the type of hazardous wastes that
10 were dumped here, overall by a factor of at least 800-1000% as related to the volume, the toxicity
11 of its components, damages and more. For example, the proven and inferred amount of asbestos
12 pipe dumped here by defendants of more than 16,000 pounds, has been reduced by several of their
13 experts, in sworn (false) declarations, to essentially zero: Their primary, site investigating expert on
14 the topic Ferriman eventually concluded in his sworn statements that maybe there is one small
15 asbestos pipe fragment here, but were not even sure about that, because maybe that wasnt the one
16 that was tested.... In other words, maybe theres not even one, but NONE (asbestos)42.
17 41
1000 yd. is based largely on our new 5-foot deep boring described above which was also aborted on a
concrete or asphalt block, however we had initially calculated that the fill was only about 3-4 feet deep at
18 that downhill tree location. Now the inferred depth of the fill at that point is 6-8 feet deep which could
effectively at least double all of the volumes within about 50 feet of that boring. Our depth and volume
19 measurements are based on hundreds of individual data points including Remingtons hundreds of
20 excavations and John Aveggios superlative field estimating methods based on his 30 or so years of
relevant in the field volume estimating experience. Remington also had the benefits of extensively
21 studying the fill volume in the field for many years, and also used much more competent, precise and
lengthy diagrams and multiplicative methods which eventually added-up about eight different calculations
22 from 8 different complex volumes, which as a group encapsulated the entire dump, on this very steep and
irregular slope. Gwinn used a seventh grade, improperly-modeled, purported solid geometry method,
23 which erroneously assumed complete regularity and therefore made a single totally regular rectilinear
volume calculation, which was (laughingly and knowingly) totally invalid and useless on that irregular
24 terrain, as we will prove at the next trial, but it takes maybe an hour to explain using slides and/or to draw
25 it all on a blackboard.
42
Obviously, Gans coaches all enterprise experts to lie, mischaracterize and understate all of their
26 environmental pollution findings and/or observations. On delete, most of their experts have not even
visited the contaminated sites and therefore dont know what contamination exists or where. As explained
27 elsewhere for example Gwinn just sat in the shade 100-feet above the main contaminated water areas while
Remington, Gans and Ferriman went down and looked at it. Gwinn is Gans major credentialed-expert but
28 shows an amazing lack of interest in any contamination at the dumpsites whether hydrocarbon and sewage
in the waters or the asbestos all over the sites. At least hundreds of pages exist on this and related topics so
Gans, et al are all very well-aware of these allegations against them and him personally for coaching all
504
1 Unfortunately and absurdly for Gans expert family we can easily prove that Ferriman
2 personally saw and examined all 23 asbestos pipes which were visible on July 6, 2011. Remington
3 physically showed him and saw him examine all known pipes that day, and he personally
4 photographed at least half of them as he saw them, and those photographs are all in the record now.
5 Gans asked him to lie about all that but its not really possible now and therefore as discussed
6 above, it is very unlikely that either Ferriman or Gwinn will be willing or able to testify for Gans at
7 any trial, however they will be called by Remington, either way.
8 Over the last six years, Gans has knowingly and fraudulently put-forth those types of
9 obviously fraudulent expert understatements and misrepresentations as fact, and several Humboldt
10 County judges have assumed that it must be accurate if Gans presented it as such.
11 c. Gans Enterprises perjuring witnesses attempted to discard Remingtons entire lawsuit
12 by falsely swearing that Remington gave permission for said dumping and also reasonably
13 discovered or should have done so long before 2006-2008 and therefore the statute of
14 limitations ran on a permanent trespass allegation. Of course, Remington does not allege
15 permanent nuisance/trespass but continuing, however the present court has so far intimated
16 that it is going to improperly impede that prosecution, despite the fact that it is clearly proven
17 by the relevant, conclusive Supreme Court precedents that it is a jury matter to determine if
18 the encroachment of Remingtons property was continuing or permanent. Meanwhile,
19 Remington strongly believes that this case would be more competently and fairly handled in federal
20 court than in state, which is one of the reasons for filing this overall contamination and RICO action
21 initially in federal court.
22 Gans preeminent August 2016 SOL trial collusive, suborning of perjury in every trial
23 witness presented is actually a not very subtle and clever, corrupt device to accomplish each and
24 every one of the enterprises above-defined objectives. Simply put Gans script was written as: In
25
their experts to essentially mischaracterize their observations. That generalization applies to all site
26 contamination from lead, hydrocarbons and sewage and all the water below the dumpsites to the asbestos
and the fraudulent twin six-inch drains which have calm the focal point and/or poster child for Gans
27 experts fraud and knowing misrepresentations. Said twin pipes were sworn to drain the fill and be the
perfect test case for proving that the fill was benign; however, now it has been proven that said pipes are
28 solid and just channel above clean spring water under the toxic feel without ever touching any of it and
certainly no water is filtering down through the fill and into those pipes since their solid. This was and
remains a major fraud and a major weakness in Gans and his experts defense .
505
1 1998, Remington saw the encroaching fill, liked it, never complained about it at all, and then in
2 John Mathsons inimitable and ignorant words, he also added that Remington said: I aint got no
3 problem with it. During the next trial, that ignorant quote falsely attributed to the more erudite,
4 highly-educated, and much more articulate Remington, will definitely come back to haunt this
5 enterprise. That well-orchestrated perjury, backed-up with a badly instructed jury and the inferred
6 consent implied by 1-2 Remington visits, was all that Gans needed for a total victory in all cases,
7 theoretically, but, not in reality. In other words, the simple corrupt strategy above could have and
8 very nearly did result in the Enterprises achieving all seven (7) of their primary general goals
9 stated above.
10 Crime does not pay?, theoretically, although it very, very nearly could have here, and may
11 still prevail. Fortunately, Remington had the time in late 2016 to understand, research and think
12 about how to defend against Gans Enterprises Mafia -like ruthless treachery and continuous and
13 increasingly ominous criminal acts.
14 d. Evidence spoliation. Another primary and successfully executed Gans plan and method to
15 avoid all liability and all cleanup costs here, plus realizing all of the other objectives, was to order
16 soldiers John Mathson and all his primary helpers and family, including Skillings, Kishpaugh,
17 Randall, Hilfiker, Evans and Costa, et al, to not only terrorize Remingtons fences property and
18 peaceful way of life in all the ways complained about above, but here to specifically remove all
19 visible adverse materials that were visible on the surface of the dump, especially the numerous
20 excavated asbestos pipes, lead and other poisonous rusted metal objects, plastics, building
21 materials, rubber tires and other unsightly objects, which are clearly out of place in a near-Virgin
22 redwood forest.
23 The enterprises reasons for that superficial hazardous waste sites surface broom-sweep is
24 obvious and has been rather thoroughly explained above. Removing most or all of the incriminating
25 visual evidence makes conviction harder.
26 If a jury cant see the evidence because its invisible, buried or because some of it has already
27 been removed, how are they going to convict, especially where the enterprises perjuring
28 witnesses all say that they didnt remove anything and could not have removed anything,
because it was never there in the first place! All of the hundreds of photos which show a
506
1 contaminated hazardous waste dump there for many years mustve just been doctored or
2 something!!
3 Facing five or six smartly coached and directly lying and perjuring trial witnesses is a
4 rather formidable task, but were dealing with it, and intend to seriously impeach them at the next
5 trial, with a few more years of preparation. In federal court, after we go to the considerable trouble
6 and difficulty of proving perjury then at least there will be real penalties faced by the family
7 perpetrators.
8 Remington likes to use the analogy that: Had OJ removed the bodies and hosed-down the
9 Bundy crime scene sites a few hours thereafter, or in this case a few years later, it would have been
10 harder to show the jury conclusive visual or scientific evidence. Here, Gans has been able to
11 conceive of such a risky and unlikely plan because Remingtons key experts that would refute all of
12 that disingenuousness are now either: DEAD (SHNs Aveggio); Removed by corrupt inducements
13 and/or other interferences (SHNs Foget); Almost removed by technical legal trickery (Dr.
14 McEdwards); or improperly and unbelievably barred from testifying about that topic by a court that
15 has been making many odd and irrational rulings (Maje Hoyos). That essentially leaves only
16 Remington and his possibly (according to Gans deceitful commentaries) doctored photographs,
17 and Remingtons apparently somewhat unlikable and over-zealous and/or irritating attitude in the
18 court room (or whatever it is) while serving as a party and his own lawyer, makes refuting 5-6
19 perjurers difficult and maybe impossible, in some instances. THEREFORE, considering all of that,
20 Remington is gathering more witnesses and will use a trial attorney in the future as or if needed.
21 In conclusion as to this evidence spoliation point, Gans enterprise has cleverly determined,
22 planned and executed the false and fraudulent sales presentation to a jury that: If there is no
23 contamination visible on a contaminated piece of land because it is all invisible, deeply buried such
24 that none of it is visible on the surface, then said property is not really contaminated. A sale of a
25 clean, broom-swept looking wooded property as a contaminated property is a difficult sale to make
26 to a jury, when a snake oil salesman like Gans is saying that there is no contamination as your eyes
27 can plainly see.
28 In that case, it becomes largely a technical exercise in ground radar, metal detection below the
surface, the results of many hundreds of excavations, expensive time and training of independent
507
1 experts as to all details of the problem and perhaps most importantly the use of credible scientific
2 testing, presented by a credible expert with full explanations of why hydrocarbon, lead, asbestos
3 and E. coli/coliform bacteria are not visible on the surface of the dump or in the photographs, but
4 nevertheless are still there, STILL are a health hazard and definitely need to be removed.
5 e. Physically covering-up and concealing evidence. An additional aspect of Gans cover-up of
6 the evidence and minimization of the adverse impacts of the dump on Remington, is to
7 systematically cover-up several dozen huge contaminated reinforced concrete and asbestos blocks
8 which stick about of the ground and weigh up to 20,000 pounds each. Gans and Mathsons
9 minions, and RICO soldiers do that with various organic materials especially spreading redwood
10 needles by hand and planting lilies, nasturtiums, English Ivy and other types of weeds on the site to
11 effectively cover-up most of the largest most adverse looking wastes. As a not unexpected result
12 Gans corruption and deception has mostly worked in that the photos taken in 2016 show almost
13 nothing visible on the surface of the dump, whereas the 2008 photos show clear and unmistakable
14 massive volumes of buried waste which were exposed up to a foot or two at the surface.
15 On the positive side however, for Remington, is that comparing photos from the two years
16 2008 to 2016 we can see clearly and unmistakably that there has been drastic evidence tampering,
17 felony evidence spoliation, but possibly most importantly that under the important contamination
18 case, Field-Escandon, the drastic changes in the site over that time show and prove a continuing
19 nuisance, and which significantly, part of the definition is to vary over time. Thanks to Mathson,
20 Gans and their men, in addition to the natural physics of a super-steep mountain slope with heavy
21 erosion and wind forces, the site is now proven to be a continuing nuisance and trespass beyond
22 any doubt under all determinative Supreme Court case criteria, and most especially that: the sites
23 are reasonably remediable for reasonable cost in addition to varying over time, whether the state
24 court credits the water contamination tests or not.
25 f. Improperly influencing the initial and primary state trial judge or worse has also been an
26 enormous deleterious force on these cases, and still is. Now is not the proper or prudent time or
27 place to diplomatically dissect all of the problems and perceived state court-ruling errors that
28 have occurred here during 2016, however as objected to contemporaneously, and in the first state

508
1 Court of Appeal, Remington objects to numerous Judge Reinholtsen trial and pretrial court
2 decisions.
3 Whether they were proper, correct and/or corruptly influenced remains to be seen, but
4 certainly is under very active investigation.
5 Many of the perceived errors and serious problems Remington has had with some of the
6 pretrial rulings involve literally hundreds of Remingtons exhibits including more than 100 good
7 clear, colorful graphic trial charts which summarized Remingtons eight (8) years of excavations
8 and investigations, which appear to have ALL been barred merely because they were done
9 creatively and scientifically in Photoshop, and therefore were artistic or graphical departures from
10 pure unedited photographs. An expert, such as Remington in these cases, should be able to
11 graphically portray exactly what his opinion is based upon, how and why, and then obviously He
12 (here Remington and/or Dr. McEdwards) should be able to explain on direct or cross what
13 alterations he made to any photographs or what assumptions were made regarding all levels of his
14 presentation and opinion. Possibly, this court would let a qualified expert do what Remington has
15 attempted to do, and possibly that is not yet an issue at this point. Remington has not yet been
16 qualified as an expert by Judge Reinholtsen, but such examination was scheduled and presumably
17 will be again arranged, in due course.
18 6) Punish and Torture Remington further, beyond mere monetary and emotional destitution
19 and bankruptcy. Gans Enterprises final and obvious crucial objective is to further punish,
20 torment and damage Remington completely, and indefinitely, by whatever methods it takes,
21 including:
22 (A) Subjecting Remington to this unpleasant and costly never-ending litigation with endless
23 motions, witness costs, until he goes into bankruptcy, and continuously harass him as recently, with
24 nothing but disingenuous lies, false motions in limine, overly simplistic and bad special jury
25 instructions, and solid mischaracterizations, to oppose;
26 (B) Kill him if necessary or reasonably possible by literally physically poisoning himFrom
27 stirring up noxious toxins on these dumpsites, and/or wearing-him-down mentally and physically
28 until he dies of stress or old age. Or, if that eventually fails, the enterprise has several soldiers

509
1 capable of violence, and taking-care of Remington in other ways, as remains to be determined
2 and as worried-about above;
3 (C) Break his spirit psychologically with improperly influenced, unjust judicial decisions,
4 continuous vandalisms every few days, and never-ending property damage. Make living along
5 Westgate totally unpleasant, keep his property and estate value ultra-low, where eventually hell
6 have to virtually give the property away or rent it for a mobile home or similar. Ultimately, the
7 Mathsons, et al are desperate to drive Remington from this area to gain a final and total victory
8 against Remingtons arrogance and his too big house (JOY Mathsons characterization), which
9 admittedly makes the Mathsons feel inferior and perhaps does make their travel-trailer, driveway-
10 mechanic based surrounding residences, look shabby and below-standard, at least in their own eyes
11 apparently.
12 (D) Cause Remington endless worry and fear from: The enterprises numerous threats and
13 many forms of extortion, such as worrying about the almost daily major vandalisms and other
14 crimes against his property; The numerous attorneys involved here and what motion or frivolous
15 document they will file next; The nearly continuous defendants complaints to about 40 public
16 agencies, and the resulting public pressure from those governmental agencies and from the public in
17 the neighborhood; Their almost constant simple coercion, intimidation, plus the unpleasant almost
18 continuous early morning simultaneous vandalism and motion activity, which as Gans is well-aware
19 of is unnatural for and hard to deal with on Remingtons biological clock; The possibility that
20 defendants torture and criminal acts will never end until after Remington is gone, and then would
21 likely continue when his daughter and granddaughters take over the estate, making it difficult or
22 impossible for them to enjoy the magnificent house and grounds and probably almost impossible to
23 ever end this present feud. Mathson also has heirs which may continue this war against
24 Remingtons culture, educational values and against the big house, indefinitely. There also
25 remains the FEAR and very imminent possibility that John Mathson, Skillings or one of the other
26 soldiers may again attempt to burn down Remingtons house structure, as they nearly accomplished
27 in September 2008 when these lawsuits were at their very highest intensity of all. The details of that
28 partially successful arson which DID start an enormous fire in Remingtons house, (however
Remington just barely managed to put it out himself, because the fire department took about 10-
510
1 minutes to get here), are not important in this document. The incident is mentioned here, because
2 we now know that a repetition of that is always a possibility. That incident did not make the local
3 or national TV news, nor was there ever a direct witness to any positive Mathson act, because he is
4 very cautious, wily and careful, but it certainly got Remingtons full attention, burned-him
5 seriously and instilled fear which lasts today. However, at some point the burglary, sabotages,
6 window breakages and an enormous rare garden damage may become newsworthy, especially when
7 convictions are attained, after further discovery here. Eventually we and tend to catch all the
8 primary leadership perpetrators, and hopefully that will bring-down The Godfather and the evil
9 Empress that finances them, all around the same time.
10 Gans enterprise has effectively established a reign of terror here. Their main stock in
11 trade is, and has been to make Remington constantly afraid, fearful and anxious no matter what
12 activity he is pursuing or what his garden-work intentions are before he gets to the site each day.
13 Above all, that fear, daily unpleasantness and constant great unpredictability as to what dire
14 acts of violence against property or Remingtons person will occur next, are what makes this
15 enterprise insidious, horrible, a constant torturing presence, and explains why Remington is now
16 determined to expose it, kill it and bring it to justice.
17 For example, there are arguably few more beautiful and relaxing places on earth than
18 Remingtons extensive mountainside rose and fall-color foliage gardens, under 300 large redwood
19 trees. Nevertheless, after various of the aforementioned escalating incidents in both 2014 and
20 2015, Remington subconsciously felt enough fear, anxiety and a possible threat against his
21 personal safety to have carried a loaded pistol around and even wore complete torso and
22 other body armor for several weeks on several occasions until conditions and relations between
23 Remington and the enterprise softened somewhat. Remington now understands when, where and
24 how he can carry loaded firearms legally on his person or in his car, as needed, and the need
25 inferential he will resurface again, during 2017. Remingtons grandfather Frederick Remington was
26 a national police pistol target shooting champion in the 1930s,Taught Remington how to target
27 shoot accurately since age 8, and he had an exceptional collection of accurate pistols, plus a couple
28 of rifles which Remington inherited 50 years ago.

511
1 (E) Generally, by means of the above and all the other factors not mentioned here, as
2 explained, Gans seeks to punish Remington indefinitely, destroy him financially and perhaps even
3 after hes been driven into the grave for his generally arrogant attitude towards Gans and these
4 trailer trash neighbors, and for Remington's clear and longtime recognition of Gans corrupt,
5 unethical and criminal activities in defending these cases, and for Remington's great audacity in
6 standing-up for justice against the mighty and pretty arrogant Gans, for 10-years now.
7 Therefore, in retaliation and for Gans perceived retribution, Gans now seeks to cause
8 Remington further extreme emotional distress, and then finally to sue Remington for Gans long-
9 time stated goal and intent of recovering punitive damages and malicious prosecution damages
10 from Remington, to fulfill the Enterprises ultimate objective of suing Remington for some sort of a
11 multi-million-dollar verdict after all the contamination cases are over, and after the enterprises
12 anticipated intermediate victories.
13 F) Remington now experiences a feeling of dread, tension, anxiety and possibly impending
14 doom whenever he comes to his offices and estate every day for 8 to 10 hours, with Mathson
15 generally waiting and watching for him, about four hundred feet away by his mailbox. Working
16 outside within sight of Mathsons land, Remington can never relax now and never let his guard
17 down completely because Mathson watches continuously from his secure, well-concealed game
18 blinds with a telephoto camera lens constantly aimed at Remingtons land and Remington
19 wherever he is working, as explained above.
20 7) Gans stealthily covers-up his criminal RICO enterprise by cleverly pretending to be just
21 an ordinary ethical defense attorney facing an overzealous, crazed pro per litigant
22 Remington. The actual truth, however is very different from Gans pretenses, and has been
23 described herein.
24 The real truth is that the reverse is true, however it will take a few months for a new court to
25 understand all that. There are many thousands of pages in the court records here which are perfectly
26 ordinary offense and defense motions, demurrers, motions to strike, amended complaints, numerous
27 long declarations and summary judgment motions. Ostensibly a perfectly normal state and federal
28 court record, especially for the first several years, until one studies it closely.

512
1 Remington first studied what Gans was doing and wrote about it under penalty of perjury in
2 his federal summary judgment opposition where he first began noticing and studying Gans skilled
3 and incessant use of false logic, with always one or more false premises, and hence always false
4 conclusions to some extent; his use of almost continuous mischaracterizations and extreme
5 hyperbole; all of which graduated into some perjury, plus some other serious factual transgressions
6 began appearing by mid-2011, but by 2012 Gans had definitely crossed-the-line into multiple
7 criminality as described and alleged herein.
8 Simultaneously, there was increased perjury in filed documents, and multiple misdemeanor
9 and felony vandalisms began increasing all over Remingtons estate, including various dirty tricks,
10 burl and machinery thefts, burglary, broken windows and one attempted arson had all become
11 manifest and serious by 2012, and also some of that occurred earlier. The first provable serious
12 extortive act and blackmail occurred as explained to Remingtons star witness and remediation
13 contractor Bob Figas, beginning in very late 2012 and escalating in magnitude and damaging effect
14 during the first several months of 2013. Therefore, by no later than January 2013 the official
15 existence of Gans criminal RICO enterprise that fully emerged has been quite thoroughly
16 explained herein.
17 [5 (e), (f) and (g): The less widely used RICO statement details to explain, which are also
18 believed by Remington to be important and relevant here, as set forth below].
19
5 (e). State whether there has been a criminal conviction for any of the predicate
20
acts/incidents of criminal activity:
21
Not yet, as criminal charges have not yet been sought, but that process will be started and
22
pursued beginning in January-February 2017.
23
John Mathsons and Gans other soldiers vandalisms, burglaries and related general property
24
damages all over Remingtons property, have been complained of for years to the sheriffs office
25
without any particular success. When Remington was in the burl business in Eureka and had stores
26
from Myers Flat to Crescent City, he had literally several hundred known burl thefts during that
27
time, and at some point found it to be ineffective to report every incident to the sheriffs and spend
28
time investigating and doing reports that led to nothing.

513
1 Instead, Remington spent that time upgrading his fences, employee education and other
2 security measures and found that to be an acceptable solution. Here when Mathsons crimes have
3 been specifically reported to the Humboldt County Sheriffs Department and investigated, they just
4 denied any knowledge of them and without specific witnesses or surveillance cameras, that we have
5 now, nothing much came from reporting crimes to the Sheriff. NOW, we do have lots of
6 photographic evidence and even one witness that caught him in the act that has been very
7 specially saved for trial impeachment.
8 There were several exceptions to that which Remington self-investigated and did locate the
9 stolen merchandise and perpetrators in two cases involving sales of stolen Burl to Native Woods
10 and Burl Wood Industries, and four (4) other major-gigantic burl thefts back during the 1980s and
11 90s when Remington stored his burl along Broadway, involved his own employees, and all four
12 incidents were solved and the employees were fired or died in one instance. However, since
13 Remington moved all of his good burl up to 832 Westgate in 1998, there have been dozens of other
14 more minor thefts and incidents by local thieves that were never solved, and the only viable way to
15 remove burl from Remingtons property is across Mathsons driveway and through his front yard.
16 If Remington had the surveillance cameras he has now back in the 1970s-90s, he would have solved
17 or aborted many thousands of dollars of burl thefts.
18 Today, we have numerous surveillance cameras and only two locations which run 24-7 and
19 have many hours recorded of numerous flagrant Mathson trespasses, other incidents and related
20 suspicious activities, with typically scores of hours not yet watched. Mathson however is very wary,
21 cunning and knows he is guilty and being watched constantly; therefore, he watches carefully now
22 for cameras before he commits criminal acts, and hence he is now ultra-cautious, but after several
23 years of surveillance, we probably have just about enough now so that we can rely on a jury next to
24 determine what justice for him will be.
25 We also probably have enough conclusive and circumstantial evidence of Mathsons, Gans, et
26 als vandalisms, burglaries and many other crimes to go to the district attorney with and will be
27 doing so after this is filed. Our surveillance video and still photographs of defendants serious
28 evidence spoliation is still very strong and it will have to be presented to Judge Reinholtsen or

514
1 another court for some sort of serious, or terminal evidentiary sanctions since spoliation itself is no
2 longer a California felony.
3 5 (f). Describe in detail the perceived relationship that the predicate acts/incidents
4 of criminal activity bear to each other or to some external organizing principle that
5 renders them ordered or arranged or part of a common plan:
6 Very clearly and very consistently all of the RICO enterprises alleged predicate acts herein,
7 clearly, completely and 100% pertain to the enterprises purposes, objectives, common plan and
8 goals quite thoroughly expressed with specificity, herein.
9 (1) 5 (d) above thoroughly explains in detail specifically how the enterprises unethical,
10 criminal and federal predicate acts advance Gans organizations obvious objectives. Everything is
11 there. Gans has for years had very detailed plans, devices, unethical and corrupt intentions and
12 thoroughly executed all of them as revealed in the very lengthy administrative and trial records.
13 Simply put, the Enterprises intentions and executed plans, as proven by a detailed analysis of what
14 work and activities they have actually done, over the last several years, have been to:
15 Unconditionally WIN these lawsuits; Hurt, punish, injure and if possible totally crush
16 Remington as best possible and as soon as possible; Drive him away from these sites and force
17 them to end this litigation, taking nothing for himself, while owing the RICO enterprise several
18 hundred thousand dollars; Prove that Remington caused all contamination on both sites and that
19 Mathsons property is clean, pristine and can be legally sold, whereas Remingtons property is all
20 contaminated and hence not salable or marketable except possibly for pennies on the dollar at some
21 sort of a bankruptcy auction. Additionally, of course the enterprise wants to: Save themselves
22 money, avoid all cleanup costs, keep ALL of Remingtons occupied land free of any charge, torture
23 Remington as best they can as they proceed with their corrupt plans and objectives, provide
24 themselves with ethical and legal cover as they proceed to try and stay out of jail, and of course
25 make as much profit and high salaries for themselves as possible.
26 (2) What is the pattern, order and consistency of the criminal acts by the Enterprises members
27 and are they very clear and obvious in their intentions and purposes? To Remington they are,
28 and he has therefore provided considerable detail about the enterprises criminal activities over the
last several years. Possibly too much detail or too much redundancy, however again he approaches
515
1 this question thoughtfully, originally, all from his own personal experience and he is not just
2 copying text from some other part of the document.
3 a. The cutting of Remingtons fences and related vandalisms by Mathson, and his deer and
4 bear armies, all presumably aided by some of the other local enterprise members which would
5 include Evans, Kishpaugh(s), Costa, Hilfiker, Randall and Skillings for starters, has been explained
6 previously. That particular act was well-thought-out and carefully planned for several years before
7 it was routinely executed almost daily. Beginning back as early as 2003-05, Remington had
8 numerous pleasant conversations across the fence with John Mathson wherein Remington
9 essentially complained about his problems keeping the local deer and bear out of his gardens.
10 That was Remingtons pet peeve and about all he was seriously focus on for parts of several
11 years. Remington spent at least 5-6 total hours of emotional conversations spread-out over 15-30
12 separate friendly neighborly conversations with John Mathson, concerning what Remington had
13 unsuccessfully tried, what specific damages had been done by which specific type of beast, what
14 Remingtons next plans were and what Mathsons advice might be, other than the general sympathy,
15 and the just listening service which he always offered. John Mathson was always interested in
16 these animated conversations mostly about animal and security fence problems, prior to 2006, and
17 we even had several after that, while the general concepts, emotional Remington complaints and the
18 obvious mental and physical torture of Remington and his freely- expressed anxiety and continuous
19 fence modifications and reengineerings which took place, percolated around in Mathsons mind for
20 several years. John Mathson knew for years what Remingtons worst nemesis and fears for
21 his gardens were and just listened sympathetically about it until both Mathsons turned hostile
22 around 2006-2008. It was not until June 2008 before Mathsons and/or his friends and fellow
23 users first began their initial deliberate security fence cuttings and the predictable immediate
24 destruction and annihilations of Remingtons many thousands of rare plants, which have been
25 thoroughly documented and extensively complained of in numerous declarations and amended
26 complaints since June 2008.
27 b. By summer 2008, the Mathsons were in a total war with Remington and wanted to hurt
28 him severely with a preemptive strike in July and August 2008 with the obvious intention of
seriously intimidating and scaring him in order to prevent him from filing his expected and just
516
1 contamination lawsuit. Remington did file that suit DR080678 a few days after defendants filed
2 their lawsuit, however Remington served his suit on the Mathsons before they served Remington.
3 Hence the lawsuits were developed simultaneously, however Remington spent most of five
4 months doing his work, whereas Gans probably did his cursory, retaliatory only and frivolous
5 complaint in only a few days. Gans DR080669 complaint was never planned to be a serious
6 lawsuit and was merely a retaliation to the complaint they knew Remington had in progress. Their
7 complaint was an obvious extortive attempt to either stop Remingtons complaint from ever being
8 filed and served, or later it became merely an attempt to offset Remingtons legitimate suit with
9 their illegitimate suit, so that a jury might just cancel both complaints out, and call it even. That
10 wouldve been completely unfair, which was of course why Gans had planned it that way. Gans had
11 no enterprise then perhaps but he has seriously lacked any proper, good California attorney ethics
12 ever since this started in 2007-08.
13 c. In other words, Remington always had at least $100-$200,000 of legitimate cleanup costs
14 and related damages, which defendants fully acknowledged in the August 2011 settlement
15 conference. Whereas Gans and Mathson never had any legitimate damages other than for
16 Remington to remove and slightly relocate his fence a few feet southeast which he agreed to do at
17 least 6-7 years ago. Even had Remington not agreed to remove that fence, Mathson still never had
18 damages of greater than $1-10,000, if that. Hence the $20,000 they eventually received from
19 Remingtons insurer, Farmers, in order to save themselves $100-$200,000 as explained above, was
20 a big windfall for Gans and Mathson because their lawsuit was never really worth anything nor was
21 it intended to get any monetary damages. Gans was going to use it to prejudice the jury in a
22 consolidated trial but very conspicuously when defendants offered Remington approximately
23 $100,000 or more to settle his case, Gans case DR080669 was never assigned any value whatsoever
24 and was just ignored completely in those settlement negotiations, as though it were worth zero
25 dollars.
26 d. It can be inferred now that when Gans heard the above story about how destroying
27 Remington fences and letting deer in to destroy his rare gardens was of serious concern to
28 Remington, Gans was obviously pleased to hear all that, and probably did not have to be told it
twice. It is known today that Gans gave Mathson lots of encouragement about continuing his
517
1 harassing acts of vandalism and Gans has even been seen to laugh with unrestrained enjoyment in
2 Remingtons presence at the beauty, difficulty of detection, ready deniability and apparent benign
3 non-criminality of Mathsons continuous sabotages of Remingtons fences, gardens and related
4 property. Naturally, Remington sees all of that very differently as explained herein.
5 Gans tried a variety of other harassing, intimidating and/or extortive acts on Remington over
6 the years such as the serial complaints to more than 40 different governmental organizations of
7 every type and level cited above and in trial charts number 12-13. Those complaints were very
8 deleterious and wasted a lot of Remingtons time, intellectual energy and emotions, but they never
9 stuck, had serious lasting monetary damage or had any of the impact of Mathsons and the
10 Enterprises over 100 serious fence sabotages, each of which stole an average of 5-8 hours of
11 Remingtons time and caused nearly $1000 of damage on average. The fence sabotages were BIG,
12 very important and had known serious and long-time impact on Remington. Because that was
13 well-known to defendants, Mathsons vandalism and attacks with his deer Army persisted for
14 years and still continue today in 2017.
15 e. More on Mathsons vandalism and deer army.
16 John Mathson is known to love watching Remington scurrying-around the mountainside
17 chasing deer, looking for fence holes, patching them and bringing-in dogs which which often were
18 effective, but other times were not.
19 Mathson has often been seen standing-there watching with this camera in hand for months at
20 a time, obviously and blatantly just hoping and praying that some baby or delicate young female
21 deer will be injured or killed, so he can photograph it and charge Remington with criminally
22 injuring or killing deer of all types. It seems clear that the Mathsons and Gans almost live for a
23 retaliatory act by Remington that they can use at trial or criminally. Anything, like a poisoning or a
24 cross-bow attack, for example, would be perfect for Gans to use at trial to prejudice Remington.
25 Remington has a neighbor that has almost begged him to allow him with his bow and arrow
26 to shoot deer on Remingtons land, however that is inhumane and Remington essentially likes deer,
27 from afar and in the abstract, like Bambi, and he is unwilling to condone such attacks on young
28 undefended deer or on any animal.

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1 Further, after Mathson cut holes in the fence or unraveled them enough for deer to go
2 through or under the fences, then often Mathson could not resist following them in himself to
3 sabotage Remingtons crucial irrigation tanks and reservoirs; break and otherwise damage his drip
4 irrigation systems or major trunk lines from one part of the property to another; break windows on
5 the house or vehicles and/or steal valuable burls and mill machinery which are stored randomly all
6 over Remingtons property. Unfortunately, most of that vandalism and theft occurred before
7 Remington set-up his extensive surveillance system, however, which eventually will catch
8 Mathson, Kishpaugh or Skillings in a recorded criminal act. John Mathson especially seems to be
9 literally crazy, addicted to the adrenaline, laughter and obvious praise and respect that he gets from
10 Joy Mathson. Joy would undoubtably love to do all of that damage herself, but has to live-out her
11 hostility vicariously through John, Remington surmises. Unlike a Godfather female, Joy Mathson is
12 clearly deeply involved in the family business and obviously thrives on it, end is an important
13 accessory to its execution.
14 f. Additionally, as part of the Enterprises plan and pattern to crush and torture Remington and
15 to win these cases 100% no matter what it takes, has been to harass, remove and/or disqualify all of
16 Remingtons environmental experts to date. So far, all have come and gone, been disqualified or
17 severely crippled, to date. John Mathson plays a pretty important part in that in that each and every
18 expert that Remington is ever invited here to investigate the property, plus Remington himself, have
19 been terrorized, intimidated and made to fear for their lives. Mathson obviously prides himself on
20 his successful intimidation and waits patiently for every expert, or any visitor, especially when he
21 knows they are coming such as Dr. McEdwards (on February 15, 2016), but otherwise hes always
22 just there ready and waiting.
23 For example with Aveggio and Foget in 2012, Mathson waited until they got fairly close and
24 then jumped out from behind a big tree and yelled angrily at them like a crazy psychopath, startling
25 them and making them afraid of what he might do next. What he does do next is often to start
26 taking unexpected flash pictures which in the twilight under a dark redwood forest simulate
27 gunshots with a silencer. Mathson does that a lot while Remington is working by himself but also
28 reprises that startling routine whenever anyone visits. Those irrational and angry acts are just some
of the dozens of similar actions and problems which Remington just has to accept and live with, but
519
1 it does cause anxiety and takes most of the fun out of doing any work within sight of Mathsons
2 land.
3 g. John Mathson has taken literally thousands of bad photographs of Remingtons property
4 and Remington at work weeding, spraying, watering, walking, urinating and irrigating. Mathson
5 never tires of photographing Remington at work. He knows that in GansI adept, devious, deceitful
6 and unethical hands any photo can be used for an evil, deceptive and entirely dishonest purpose so
7 John Mathson has taken literally thousands of these bad meaningless photos over the years. Gans
8 can use these photos to improperly infer and to argue that they portray Remington poisoning,
9 spiking the ground with hydrocarbons and otherwise polluting the environment with herbicides,
10 fungicides and essentially all of the poisons which Remington alleges that Mathson and defendants
11 deposited on Remingtons property, when they originally dumped 2-3 million pounds of hazardous
12 wastes there around 1998 and afterwards.
13 h. The organization of Gans RICO Enterprise soldiers and Associates on the ground
14 received clear-cut orders, which were consistent, carefully structured and/or arranged and clearly
15 follow the common plan which would be dictated by the above explained enterprises overriding
16 governing purposes and short and long-term objectives.
17 Although perhaps somewhat redundant, Remington here reiterates who the primary daily
18 soldiers on the ground are, whom Gans supervises and issues orders to or through, generally
19 through chief field-extorter John Mathson, who is the central neighborhood GANG leader and
20 Westgate crime boss. The enterprise is mainly made up of Mathsons local neighborhood friends,
21 drinking and drug buddies, former pulp mill union members and high school friends and other
22 associates. John Mathson does not work at all, has no known hobbies or other interests besides
23 riding around on his big sit-down lawnmower and most importantly his central activity since 2007
24 is plotting against Remington and discussing, slandering, abusing and otherwise bad-mouthing
25 Remington to all his local friends, co-perjurers plus anyone else walking along the street in front of
26 his house, who will listen to him. Mathson loves doing that, has nothing else to do all day long most
27 days so he can fully devote almost all of his time to RICO enterprise business activities.
28

520
1 Said friends and co-perjurers consist of, without limitation: Costa, both Kishpaughs, Randall,
2 Skillings, Evans, Hilfiker, Mathsons daughter, all of their experts if or when they ever visit, Gans
3 himself and many others.
4 Most of those live nearby here and their close association largely explains how Gans coached
5 four (4) other witnesses to consistently backup John Mathsons fantasy-scripted and well-coached
6 perjury about nonexistent events which never occurred in 1998.
7 John Mathson himself was the only one who said anything of substance and all the others
8 just said yeah, Remington was there then, just as our best friend John said. Not a one of them
9 heard the purported conversation with Remington, probably because it never occurred at all, but
10 the jury assumed that all of those nice regular guys led by that personable and charismatic Gans,
11 were telling the truth when in fact they all were lying on that one material topic that they were
12 called to prove: namely that Remington visited massive land 18 years previously, which never
13 happened. Therefore, no one needed to hear any conversation but just verify that Remington had
14 been there and therefore had been put on notice of the contamination of his land. That was all very
15 simple, cute, clever and corrupt by Gans to figure-out that criminal perjuring strategy, but
16 Remington intends to make sure he does not get away with that.
17 How or why five people all pretended to remember something so insignificant, so clearly, so
18 consistently and so amazingly unlikely, that one ordinary local guy, who not one of them knew
19 by name in 1998, just happened to be walking over to and around an irrelevant property a full 18-
20 years ago, was never questioned or doubted by the jury under Gans deft and skilled con-artist type
21 questioning. His honesty and integrity were assumed, but assumed wrong.
22 Hopefully this court will not fall into that trap and will make him defend each and every one
23 of these allegations and not just laugh them all off without any defense, as he was allowed to do by
24 Judge Watson during the last CCP 128.7 motion hearing, and by Judge Reinholtsen in August
25 2016. The next such hearing should be Gans answering these federal criminal and perjury charges
26 and not just ignoring ethics violations.
27 The above batch of bums will never be able to tell the same story consistently twice three
28 years apart with a detailed foundation already laid at the 2016 SOL trial, plus intervening
depositions. John Mathson couldnt even do it three days apart in August 2016 when he
521
1 contradicted himself conclusively and severely at one point and Did not say what was on Gans
2 script and that that he directly and personally spoke to Remington himself TWICE on his
3 land in August 1998, but incriminatingly slipped and stated that he had heard that
4 Remington was there from someone else. That was conclusive proof of perjury, however when
5 Remington got the transcript and tried to explain it to the court and the jury, it was ineffective, and
6 no one seemed to care about that because their minds were already made up. With several years to
7 prepare and with a skilled defense attorney to assist him, Remington will do better with Mathson
8 and this co-conspiring bunch of bums and crooks at the next jury trial. Judge Reinholtsen, as
9 explained above, was very unhelpful to Remington on this issue and about all other trial matters, as
10 explained above. Had the court made any one of a dozen different rulings, the 2016 trial outcome
11 might well have been different. For example, had it allowed in the incriminating sworn defendants
12 Special Interrogatories, wherein Gans and Mathson did not disclose any part of their perjured 2016
13 trial testimony, because it was not even fictionally written until about a week before trial, or had
14 said court admitted any of Remingtons critical impeachment photographic exhibits, devastatingly
15 important and conclusive 2003 photographs which destroyed star witness Skillings testimony
16 110%, or had it admitted other Remington relevant artistic drawings, any one of those altered
17 rulings would have made a big difference.
18 5 (g). Explain how the predicate acts and incidents of criminal activity amount to,
19 or pose a threat of continued criminal activity.
20 1. Gans, Mathson and their soldiers vandalistic in criminal activity is a long-term
21 process that has been going on continuously for 8 years, and increased exponentially during
22 2015. Since its been working effectively and defendants have said that they are especially angry
23 right now, theres no reason to expect it to stop anytime soon. In fact, as explained above every
24 week or two the last break-in occurred only two days ago in mid-March, 2017. Perhaps if
25 Remington had ignored it or pretended that it was having no impact all along, possibly they would
26 have stopped it, however Remington has written extensively about it in declarations and amended
27 complaints, so that Gans knows That Remington is feeling the pain as intended, and if it keeps
28 working, and continues to torture Remington as planned, maybe it will eventually accomplish their

522
1 objectives. John Mathson follows Gans around the court house and the several blocks to the south
2 like an obedient puppy dog, and if Gans says it is working thats all Mathson needs to keep him
3 (and Gans) happy and to cause Mathson and his friends to redouble their efforts. Meanwhile, the
4 enterprises continued criminal activity and the threat thereof has made most of Remingtons life a
5 living hell with little to no LEL or feeling of well-being, ever. It is very likely that since
6 defendants RICO acts have been working so far, it may be inferred that they will now redouble or
7 triple what they have been doing to make sure that they drive Remington away, sooner rather than
8 later. If Remington leaves now or soon before any cleanup is done here then Allied and the entire
9 enterprise benefits and all defendants would be feeling the pride of their job well-done!
10 To Remington, Gans RICO extortive racketeering enterprise is analogous to a Klu Klux
11 Klans meeting and a conspiracy to burn down a black church while the choir is practicing in it, Or
12 to desecrate a Jewish cemetery, and when they get away with it cleanly, the next day they celebrate.
13 2. Remington recently observed Gans, Plotz and John Mathson every day, five days per
14 week for three hours for approximately 110 straight days during pretrial hearings in spring and
15 summer 2016 walking back and forth from their offices smugly, briskly, smiling confidently and
16 laughing frequently as they basically make their easy money, committing their crimes and getting
17 away with every false argument and sophism with this ultra-Lenient and easy to deceive court.
18 Among his many other arguments, Remington extensively emphasized defendants unethical
19 behavior and criminality, however the judge was just not interested, inferentially for the reasons
20 described herein. For some reason, Judge Reinholtsen is just unsympathetic to Remington in this
21 case, which seems to Remington as analogous to a Mississippi-born, raised and educated judge
22 overseeing a Klu Klux Klan defendants trial. Maybe Remington is too arrogant, not likable
23 enough, has too superior an attitude and too fine an education, or maybe its serious and studious
24 nature or his thick glasses, we just dont know, but something is wrong and iniquitous with this
25 present state trial situation. Anyway, whatever the problem is up here, we will be remedying it in
26 the future either in a sophisticated big city, federal setting such as San Francisco, where Remington
27 is more at home, or with an experienced trial associate in future Humboldt County trials.
28 So to reiterate, Gans is guaranteed to continue this criminal activity as long as it: 1) Continues
to work as it has been doing. Obviously, if it works, dont fix it; 2) Continues to make Remington
523
1 unhappy such that defendants know their work is effective, [YES, It is making Remington unhappy,
2 so keep it up]; 3) Costs Remington noticeable time, money, physical and emotional energy; 4)
3 Pushes Remington noticeably closer to the day when hell just give up and say the hell with it,
4 who needs this anyway, and that the possible several hundred thousand dollars of damages he
5 seeks here is just not worth sacrificing the rest of his life about; 5) Escapes provable detection and
6 defendants continue to get away with it; 6) Defendants vandalizing soldiers health holds up and
7 they continue to enjoy their criminal activity, since what they do is difficult physically and provides
8 their recreation like a football game or the Olympics for the primary defendants.
9 3. Gans RICO enterprise members clearly live to terrorize Remington. For example, for
10 John Mathson, it has become his lifes work, as explained above. That statement is not based on
11 some crazed irrational paranoia, but is based on Remingtons inductive scientific method
12 observations and the recording of eight years of criminal incidents plus over 100 recent straight
13 days of recent direct personal observation, as explained above. Both Mathson and Gans always
14 knew as they walked with strained over-confidence to the courtroom hearings every day, where
15 Remington was, whether he looked tired, anxious and tormented or not, and what they had done the
16 preceding several days with regards to tormenting him. Knowing it did not make much difference
17 how they acted several days after a crime, and further that acting confidently and at ease would
18 apply additional pressure on Remington before and after hearings, they never made much of an
19 attempt to conceal their gleeful enjoyment of what they were doing, especially when it had been
20 effective.
21 4. Skillings. Similarly to the above discussion about how Gans, Mathson and Plotz love their
22 work of tormenting Remington, Skillings is also a natural for his Luca Brassi-like violent enforcer
23 role her. He could play that part in a movie or here in real life, where he is living that part. Skillings
24 is a tough, mean blue-collar, drag-racing redneck intimidating type, who clearly enjoys beating-up
25 people and bullying them. He is a physically well-muscled big strong in-shape 265 pound, 6 Tall
26 heavy-equipment operator who is obviously used to pushing most people around and getting his
27 way by physically intimidating methods and not by verbally persuasive methods.
28

524
1 The surprising results of Skilling 2013 activities, told Remington about all he needs to
2 know when he successfully scared-the-hell out of a tough logging-boss Bob Figas, who manages
3 150 also tough, mean and strong men like Skillings, but does it in a relaxed, nice and friendly way.
4 Somehow, Skillings pushed his buttons and Remington is still not entirely clear how that
5 was all done exactly, or what exact words, intimidations or blackmail threats were used, which will
6 need further discovery from all involved. The only thing we know for sure is that Figas was
7 seriously intimidated, extorted and apparently blackmailed around December 2012-January
8 2013, and then for several months thereafter, as explained. The precise words and threats used by
9 Skillings, Olson and/or Gans to Figas still remain to be determined exactly.
10
6. Describe in detail the alleged enterprise for each RICO claim. 18 USC 1964 (c) is the
11
primary alleged enterprise herein and the only one that is explained in detail. 1964 (d) would
12
appear to be nearly identical in terms of this statement, however it will also be alleged below in the
13
section which follows. A statement of the enterprise shall include the following information:
14
6 (a). State the names of the individuals, partnerships, corporations, associations
15
or other entities allegedly constituting the enterprise, only twelve (12) of which are
16
named defendants, as listed on the cover page of the RICO complaint and as fully
17
explained throughout these document, however said named RICO defendants are
18
subject to future addition or subtraction. Also, see all of the above and BELOW listed
19
named persons above, and the alleged or inferred RICO relationships, which include
20
the following names, without limitation however:
21
1. The Mitchell, et al, Law Firm (5 named defendants, so far: Gans, Brisso, Plotz, McBride,
22
Kloeppel, The Mitchell firm itself);
23
2. Linda Lawrence as an individual account executive working for Allied Casualty Insurance
24
Company (1);
25
3. Blue Rock Environmental Co. (at least 3 enterprise members: Ferriman, Gwinn and their field
26
soil tester);
27
4. Points West Surveying Company (Pulley);
28

525
1 5. RAO Co, Corporation, (at least two named RICO defendants, Olson and Skillings, plus
2 additional other likely DOE defendants);
3 6. Humboldt County Superior Court (at least 2-3 RICO Associates, see below, plus possible DOE
4 defendants);
5 7. Winzler and Kelly (at least one RICO associate-Schwartz);
6 8. Jeff Nelson, CEO of SHN Corporation (plus at least two other likely DOEs: Foget and their
7 field technician);
8 9. John and Joy Mathson, two unemployed individuals;
9 10. County of Humboldt Environmental Health Division (various executives, including without
10 limitation: Larry Lancaster, Melissa Martel, Peter Esko, Mark Johnson, Paul Dalka and their
11 primary soil and water sampler, name unknown).
12 11. See also page 527-8 below for additional RICO names which have been mentioned above,
13 and as these lists change every month or so, as of March 2017 none of these lists are fully
14 exhaustive and final and will not be until after discovery and during a federal RICO trial. For
15 example, there are numerous names below for example, Kishpaugh, Randall and Hillyard, etc. who
16 today are considered to be environmental defendants, experts or witnesses, but under Gans corrupt
17 tutelage and witness coaching, they will most likely become part of the RICO enterprise by the time
18 of the next trial in either forum.
19 There are numerous other RICO enterprise members, RICO associates and/or possible or
20 likely DOE defendants or DOE members, who may work in pairs, partnerships, corporations or
21 who are just unemployed and/or are unemployable who herein are named as potential RICO
22 defendants, but today are only known to be RICO associated individuals who are working for Gans
23 But therefore they will soon need to be fully dedicated to advancing the enterprises objectives if
24 they are not fully on-board already. This latter group which follows below, like the individuals
25 named above are all primarily under Gans central control and are believed to ultimately be paid
26 completely by Linda Lawrence, but with monies mostly distributed by Gans and the Mitchell firms
27 unknown payment personnel. [Boyd Davis and the City of Eureka are involved in the asbestos
28 allegations of the contamination suit only at this point, which may or may not stay that way.]

526
1 Other present members of Gans RICO enterprise who are not yet named in January
2 2017 as defendants include, without limitation and in no particular order of priority: Gary
3 Costa; both Kishpaughs; Marcie Conn, Matthew Hillyard (of Farallon), Mike Retzloff (Retzloff
4 Appraisal Services); Christopher Watt (LACO Engineering); The Humboldt County Hazmat
5 Divisions December 2011 tester technician, name presently unknown; Morgan Randall (of
6 Piersons Hardware, plus other possible DOE RICO associates); Larry Kluck of Matthews, Kluck,
7 Walsh and Wykle); RAOs presently unknown insurer that pays Kluck; Joel Kiff of Kiff Analytical;
8 Amanda Porter of Cal Science Environmental Labs; Gary Evans; Harold Hilfiker; Liz Smith and
9 Candy B of the Humboldt County Superior Court file room; Paul Dalka, 1998 County Department
10 of Health executive; John Aveggios SHN January 2011 soil testing technician; Mike Foget, SHN
11 engineer, ETC.
12 Other inferentially possible RICO enterprise members that are ignored here in this section
13 of this draft, except as noted above where said judge for example, was discussed at great length,
14 until further discoveries are made, would include without limitation: Judge Reinholtsen, Mark
15 Hubbard, Jason Eads (of Stokes, Hamer, Kaufman and Kirk, LLP, Miller Farms Nursery, etc.
16 All of those individuals named directly above have worked for Gans and been somehow
17 involved in his RICO Enterprises objectives and battle against Remington almost entirely
18 during or after 2011.
19 6 (b) Describe the structure43, purpose, roles, function and course of conduct of the
20 enterprise:
21 As alleged above, the purpose, function and course of conduct of the enterprise is to win this
22 lawsuit against Remington, totally defeat and crush him during that process, as explained in detail
23 above with regard to the enterprises objectives, and to do all of that under Gans tight controls,
24 avoiding any detection or penalties from civil or criminal authorities, and of course while receiving
25 their ongoing continuous big paychecks from Linda Lawrence.
26 The actual organizational structure, hierarchy and detailed chain of command has been
27 explained in words herein, but is best seen and understood in the diagrammatic versions prepared in
28 43
As explained repeatedly above, the command structure, hierarchy, specific organization chart showing the
relationships and communication avenues among the RICO membership has been explained specifically
above and also graphically drawn on several Photoshop charts reproduced in Volume III, attached.
527
1 Photoshop which are attached hereto, Volume III. For years, the enterprise has effectively made
2 Gans into a kind of Superman or Goliath with a huge hammer which Gans is still using to attempt to
3 crush or destroy Remington physically by all of the legal and numerous extra-legal means
4 enumerated in these documents. Another analogy, which has not been drawn, but possibly will be
5 portrayed in Photoshop, by the time of the trial, which would be to show Gans as the BORG
6 collectives woman-like creature leader who is wired-into, and wirelessly into the entire collective
7 or enterprise, and issues all of her orders directly or through her subordinates.
8 Although the exact enterprise structure is somewhat hard to artistically represent, if you start
9 with some sort of a circle with Gans in the center as the Borg Queen, from there he issues all his
10 orders, both corrupt and with some legitimate ones mixed in, to his enterprise HIVE soldiers who
11 execute most of the crimes and/or legal and other harassing activities or forces against Remington.
12 In that type of representation Lawrence would have to communicate wirelessly with Gans to
13 give him his unlimited power and financial strength from some invisible type of array or a direct
14 line into him, as the money from Allied is the key to everything. For those not familiar with the
15 Borg stories, that doesnt especially matter, because theres nothing unusual about Gans
16 enterprise. It and GANS receive unlimited funds from Lawrence and Allied insurance and they
17 have used them now for almost 9 years in their attempts to illicitly, unethically and now criminally
18 win these cases, and destroy Remington along with that, as per the above objectives.
19
20 Lawrence is the primary nemesis behind Gans enterprise and if you eliminate her and
21 her affects, and you dry-up the money and the entire enterprise would shrivel and die within
22 a very few days, because no one in the enterprise is altruistic or especially (or at ALL) motivated to
23 work here for free, except for John Mathson and a few of his drinking, union, drug-using and high
24 school buddies, such as Skillings. They have their unemployment, disability, Social Security and
25 side-incomes, so there are 5-6 of them who just do it for the pure love of screwing Remington
26 and watching him grovel and suffer.
27 Do any of the 35-40 enterprise members care one bit about the environment, the
28 contamination of Remington Creek or the airborne toxins blowing up into the Cutten
neighborhoods? That answer appears to be so very obvious that well answer it at the next trial. As
528
1 far as this RICO enterprise goes, to Remington essentially all of the named defendants or associates
2 above are merely Gans whores in effect, and if they are not paid presumably they will stop
3 putting-out.
4 Additionally, it is relevant that Remington is named Lawrence as a separate defendant
5 independent of her employer, because Remington believes that she is a rogue employee that is
6 acting out of personal vengeance and malice which have nothing to do with her formal job
7 description, and she, similarly to, and like Gans has now become personally, angrily and improperly
8 involved to the point were she is more like a defendant than the Mathsons are themselves. That is
9 believed to have occurred after 2012 and Remington believes that if Allied was fully aware of all
10 the facts in this case that she would be removed from the Gans file and/or fired from the company
11 for bad judgment, lack of objectivity, malfeasance and certainly misappropriation of funds paid to
12 the Mitchell firm. Whether the latter mismanagement of Allieds funds was done intentionally or
13 negligently, does not matter in this lawsuit, however Remington knows for a fact that it has
14 occurred without any discovery required, and he proved it to Lawrence in 2009, but she ignored it.
15 Obviously, as above and as would apply to every defendant named in all of these documents,
16 additional detail discovery will alter and further clarify all of the presently known and alleged facts
17 in both portions of this lawsuit.
18 Summarizing the graphical charts into words somewhat: Gans has unlimited money, power
19 and resources to defeat Remington and all litigations and regulatory areas. He has numerous spies
20 and several key bribed members in several of the absolutely most crucial organizations here,
21 including the courts and the County Health Department. Very clever, very powerful, very risky and
22 very hard and time-consuming to defeat, but we intend to do it. Gans bribes and improperly
23 (impermissibly and unethically) coaches all of his witnesses, demands that they commit as much
24 perjury as needed, and he pays his experts well to sign-off on any interpretation of any issue which
25 Gans unethically wants at the time. Again, the Enterprises objectives tell it all: Crush Remington,
26 defeat him in all the lawsuits, take his land all his money and than get him to pay for defendants
27 coverups and defenses of their initial crimes and subsequent corrupt defensive litigations until he
28 has to go into bankruptcy, or worse.

529
1 As explained, Gans Enterprise is a loose group of the aforementioned specialists, small
2 businesses, lawyers, environmental technicians and supposed experts, which Gans needs to WIN
3 these environmental lawsuits. So far, he has essentially done that unethically and corruptly by
4 impressing and/or improperly influencing two judges (somehow), and next he must convince a
5 contamination trial jury that Remington is the bad guy here, and not the obvious victim. Gans false
6 narrative to a jury into the courts has been clearly defined for many years in his motion documents,
7 and could be summarized as follows. Defendants are blameless here and our hapless victims of
8 Remingtons supposedly crimes. Remington, not defendants massive illegal hauling and dumping
9 operations, caused all pollution, dissension and problems at defendants toxic waste dump, that it
10 was Remington and not defendants that imported millions of pounds of hazardous waste in
11 hundreds of dump truck loads to the landfill area between the properties, which areas are 100%
12 inaccessible to Remington by truck or any kind of power machinery. Gans false facts,
13 alternate facts and general fraud and deception preceded those purveyed by President Trump
14 by several years, but obviously they are of very similar philosophy and are singing from the same
15 corrupt hymn book. Little problems like that are dismissed by innuendo, perjury and Gans clever
16 and believable charisma, where if he says someone else caused the dumping problems, then it must
17 be true! The reason for that is that he is a very practiced experienced and expert liar, and it takes
18 several years of exposure to it to understand and see through it all.
19 In Gans presentations such as opening and closing statements the defendants are the poor
20 beat-down victims and heroes here, valiantly destroying Remingtons property day by day for the
21 only reason that they do not like the fact that Remington is suing them for removal of their
22 contaminated debris, which they actually admit to putting there. You might think that the obvious
23 contradictions above, which is to First: Fully blame Remington for placing all contaminated
24 debris on both properties, which was a physical and scientific impossibility, but that doesnt matter
25 to Gans or an unsophisticated jury; but then SECOND, on the other hand, fully admit that some
26 of their hazardous filling debris fell down the mountain onto Remingtons land directly below.
27 In other words, that is a full acknowledgment of liability for the contamination on
28 Remingtons land, and then the only issue becomes removing that debris, which has become
bogged-down in volume measurements. If they admit that they put it there, why dont they just
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1 remove it at their cost, and then volume in the cost would not be a litigation issue? Justice demands
2 that they do just that, but justice is the last thing that defendants seek here, which was why they had
3 to turn to criminal behavior, and why Remington had to turn to this complex RICO procedure.
4 Even though defendants violated at least 50 kinds of laws at every level and are massive
5 industrial-scope serial polluters, if Gans and his collusive band of perjurers swear to or infer that
6 something else is true, then at some point a jury starts to believe them. Reiterating, Gans false and
7 fraudulent thesis is that Remington did all the polluting that is now present here from his property,
8 millions of pounds worth, and then it was levitated by alien forces or otherwise traveled against
9 all the laws of physics in the universe, first 200 feet downhill, then across a deep ravine, under of
10 major creek, and then impossibly 100-feet back up a steep mountainside to contaminate and
11 implicate the poor nice Mathsons. It is a slightly difficult for Remington to write all of that clearly,
12 and obviously impossible to do it succinctly, but the situation is really rather simple, ludicrous,
13 obvious fraud and hypocrisy, because what Gans RICO enterprise alleges that Remington did was
14 scientifically impossible but simultaneously they also admit to doing exactly what they accuse
15 Remington of doing, just less of it than what the experts measure today that is actually there in fact!
16 Now Gans argues that the poor Mathsons must be exonerated and freed from Remingtons 10-
17 years of harassment and abusive litigation which from its inception merely sought justice and
18 was only intended by Remington to pay for a cleanup of defendants dumped mess, which they
19 actually fully admitted dumping, under oath during the August 2016 SOL trial. Is it unreasonable
20 to expect the litterer to clean up his mess, or pay for someone else to do so, or is it up to the
21 victim of the letter were to absorb all time and costs involved? That is about as succinct a
22 statement of the motivation behind these cases as Remington has ever written.
23 In the 2016 SOL trial, Mathsons witnesses not only admitted that they pushed encroaching
24 wastes over onto Remingtons property and buried them there, but they also claimed that they
25 showed all that nasty hazardous debris to Remington in 1998, who purportedly said Hey it looks
26 great! Keep up the good work! Thanks for the several million pounds of hazardous wastes from
27 gas station remediation projects to asbestos removal projects. Thanks for those 20,000 pound
28 concrete chunks and other dangerous asbestos and other toxic materials, which will remain here
forever, contaminating Remingtons property, destroying his pristine watershed and native redwood
531
1 forest and keep that bad shit coming, the worse the toxicity, the better! As will be further proven at
2 the next jury trial, none of that makes any sense because Remington understood contamination in
3 1998 and had arduously avoided it in all of his industrial logging activities for about 30 years,
4 especially when it was anywhere near a pristine Creek. Therefore, Remington would never have
5 approved any dumping of anything anywhere near his Creek because it was a serious fineable and
6 imprisonable offense to dump debris into our pristine Creek, and had been for many years before
7 1998!
8 6 (c) State whether any defendants are employees, officers or directors of the
9 alleged enterprise.
10 (1) Not really. Gans RICO enterprise does not in itself have a formal structure or any actual
11 employees officers or directors, who could be identified that way, as such. As explained, this loose,
12 informal associated in fact enterprise does have a hierarchy, chain of command and methods of
13 operation, which are all secretive, clandestine and designed to avoid detection. How the enterprise
14 functions and does its work is very well-known to Gans, Remington, Lawrence, Brisso, McBride,
15 John Mathson, Plotz, probably KLUCK, possibly Olson, but very few others. Gans RICO
16 enterprise, similarly to a Mafia family, is essentially invisible to the outside world, to the courts, to
17 classmates that go to school with the Enterprises children, to most of its members and associates
18 and a RICO enterprise must remain invisible, clandestine and undetected because it is very illegal.
19 Even about half of the alleged RICO named defendants, are believed to most likely not really
20 understand the full magnitude of the corrupt criminality which Gans has organized here, into a
21 formidable illegal force against Remington in this community, intended to ruin Remington and steal
22 his land and business property. Discovery will teaches more, but today it is safe to assert that all
23 RICO members and Associates understand that Remington is the bad guy who must be destroyed
24 the matter what it takes, but other than the few mentioned in the paragraph above, it is safe to say
25 that Gans keeps the enterprises true objectives and all of its purposes substantially secret. For
26 example, Remington also today estimates that potentially 10-20% of these named enterprise
27 associates conceivably may not be aware of Gans corruption, illegal activities, massive suborning
28 of perjury conspiracy, evidence spoliation and that potentially many of the names herein could
eventually face fines and possible imprisonment for being associated in or with Gans extortion
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1 racketeering here. Even those that DO know that they had been instructed to lie and perjure
2 themselves in court, and thereafter did so, likely did not fully grasp the deep rotten, criminal and
3 potentially violent, corrupt and widespread possible ramifications (to Remington and/or
4 themselves) of their past and/or future actions, or where the future trail for Gans extortion-
5 racketeering enterprise is potentially leading them ALL. Obviously, Remington can name several
6 specific RICO members and Associates as examples that he specifically had in mind as he
7 wrote every single sentence above, each of which would have different enterprise names attached,
8 however since Gans and the above perjurers and violators of other laws know who they are, they
9 can figure-out for themselves what direction to go in next, when they are asked these questions
10 under federal oath. Simply put, they can tell the truth which Remington is fully aware of, or they
11 can try to maintain their conspiracy led by Gans and see if they can safely navigate their ways out
12 of the impenetrable dark, nighttime forest Gans has led them into.
13 (2) For this RICO enterprise to be fully secretive, clandestine and undetectable in this area
14 it clearly must have no overt public footprint or presence and no formal employees or incriminating
15 organizational chart; rather, it DOES have at least 3-4 top managers, about a dozen intermediate
16 supervisors and then at least 25 other highly-paid and probably grossly overpaid soldiers and RICO
17 associates who will do virtually anything they are ordered to do, if it appears to probably be legal.
18 Most of them probably would not carry out a murder, but probably have few other reservations or
19 moral qualms about what they have been ordered to do, if their orders from Gans, and his various
20 acting Consigliores, do not appear to be especially violent or unduly unlawful.
21 After many years of careful observations, wanton and brutal attacks from various enterprise
22 members, it appears to Remington that like any criminal organization Gans RICO enterprise has at
23 least six (6), but possibly as many as 10, known members who will literally do anything that Gans
24 orders, probably including violence if it looks justified. Again, of the 12 presently named RICO
25 defendants, with another 5-10 imminently likely, Gans and his leadership can determine for
26 themselves what exactly is meant by that paragraph, which will be further clarified in discovery and
27 in subsequent RICO statements and oppositions to dismissal documents.
28 However, as of this time, Gans has not yet appeared to have ordered any known act of
physical violence directly onto Remingtons person, however the vicious dangerous animals he has
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1 lured into Remingtons rose gardens to terrorize Remingtons family and grandchildren, have been
2 very close to crossing that line. However, given the fact that quite a few of the RICO members may
3 act independently and do renegade acts of violence on their own volition, neither Gans nor
4 Remington should take any comfort from the above sentence. Further, if Skillings attempts to or
5 succeeds in murdering or harming Remingtons person then Gans would be 100% responsible, as
6 would many of these others named herein, whether they handed Skillings the knife or actually
7 bought his ammunition.
8 When or if John Mathson, Skillings, Kishpaugh, Costa, Evans, Hilfiker or Randall, etc are
9 ordered to beat-someone-up or to destroy Remingtons car or home, some of those will do it;
10 therefore, since that has not yet occurred we can logically conclude that, so far, Gans has not yet
11 ordered any violence from his gang members because he thinks his present extortive methods
12 should probably be sufficient. Gans has a strong poker hand now, which without limitation
13 consists of at least three aces including: His 5-10 perjuring witnesses willing to swear to anything
14 that he asks; One probable judge in his pocket right now; His unlimited bribery money available
15 to all his present or future witnesses (to secure any scripted testimony on any subject as needed);
16 and with plenty of cash left over for all of his courthouse informants and saboteurs, all of which
17 should be sufficient in the hands of a Moriarty-like crime boss. So far, it has been, BUT here it
18 probably will not be, if an alert and active court accepts jurisdiction over these crimes.
19 The above fake aces which Gans was not dealt, but he put in his hand from another deck,
20 deceived the Humboldt County state court system beautifully, and continue to do so. However,
21 RICO is different.
22 RICO enables Gans to be attacked in his home hive, colony or his Borg collective cube
23 even when he has personally committed no felonious act, but just ordered his minions to carryout
24 literally hundreds of them. Clearly, Gans has lost his ability to litigate and advocate truthfully and
25 on the merits. Like a drug addict, Gans is now totally dependent upon his corrupt scripts and
26 false testimony evoked from virtually all of his witnesses. Even if Gans could still operate
27 properly in the ethical legal world, it is now too late for that because he has hundreds of false facts
28 and perjury which he now has to consistently assert in federal court and under federal penalties. As
alluded to above, Gans corrupt conspiratorial tactics worked beautifully in Humboldt County state
534
1 courts under Judge Reinholtsen, but are unlikely to work as well in San Francisco federal court,
2 now that it has been fully alerted to Gans techniques, methods, corrupt and unethical practices.
3 Mr. Plotz has followed his master Gans corrupt, unethical and illegal example and orders
4 dutifully and now writes and thinks exactly like Gans. That means that Plotz now reads and
5 interprets all California cases entirely one-sidedly and literally disingenuously quotes only the
6 portions of complete opinions that favor his case and when he must use a famous case (like Beck or
7 the Mangini cases) he illicitly and improperly, under his sworn attorney oath, uses only portions of
8 each Supreme Court or other authoritative policy statements, and omits anything balanced that
9 would favor Remington in any respect, or which Gans tells him to otherwise omit, because it is
10 antithetical to their RICO purposes. These RICO attorneys have a duty under California law to
11 properly and fully state and interpret California law in a balanced manner and if an opinion does not
12 backup their position than they are free to ignore it sometimes. However, once they decide to use a
13 case they are duty-bound to state all teachings which pertain to the present issue, including portions
14 of an opinion which might favor Remingtons case, and not just cite the ones which favor their
15 position. That method has successfully deceived Judge Reinholtsen here who does not read many of
16 the important cases himself, and therefore relies upon Gans and said judges other former law
17 partners to properly and fully expound the relevant California Supreme Court case teachings. They
18 dont properly do that ever, and hence they are guilty of deceiving and intentionally committing
19 fraud on the state court, and will undoubtably attempt the same methods here.
20 For example, with respect to the Beck case, Supra,[Beck Development v. S. Pacific, 44 Cal.
21 App. 4th 1172) during the pretrial hearings on the stenographic record, both Gans and Plotz
22 deceitfully and falsely swore that Beck teaches that the only damages available under
23 continuing nuisance is a single one: loss of use. That entirely false statement duped and
24 deceived Judge Reinholtsen despite the fact that Remington orally repudiated that false teaching
25 immediately, but because Remington is in Pro per, his interpretation of California Supreme Court
26 conclusive teachings is always suspect the said court.
27 The truth about Beck is that, the first half of the authoritative sentence at issue here is that it
28

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1 actually says remediation is available, and also loss of use. Here and ordinarily, the
2 remediation harm is many times worse than the loss of use, and therefore the RICO enterprise just
3 ignores any teaching antithetical to their purposes.
4 Those types of seriously unethical behavior in violation of the California attorneys oath have
5 been frequent in Humboldt County Superior Court, but entirely ignored by Judge Reinholtsen. He
6 infers that misquoting the teaching of famous cases is normal and to be expected in the ordinary
7 course of Humboldt litigation, however since he does not read most of the cases closely himself,
8 does not fully accept Remingtons reading and interpretation of most of them; therefore, when Gans
9 quotes a cases teaching it appears that Judge Reinholtsen always takes it to the bank as a
10 California truth from an absolutely fully trusted officer of the court. As a result of that blind and
11 improper acceptance of anything that this RICO leadership writes as being accurate and truthful,
12 plus the scores of other issues and problems outlined herein, justice has become impossible in
13 Humboldt County, and this RICO action became necessary in San Francisco.
14 When Remington tries to highlight those Gans and Plotzs miscitations and to provide the full
15 case teaching, he is generally disregarded as some sort of an old foolish zealot in pro per, that
16 cannot really be relied upon to reader understand the law. That is despite the fact that Remington
17 had a far superior prelaw background as a government major at a famous Ivy League University,
18 and has followed-that-up with more than 25 years of nearly full-time legal research and writing,
19 especially in the contamination area, but he has some other specialties as well. But for his
20 somewhat advanced age, and unduly pleasant, unaggressive and relatively, uncompetitive
21 nature now at age 75, Remington argues and would swear here that he certainly has the equivalent
22 of an average California lawyer with a total of 18 solid years of all-purpose experience for eight
23 hours per day and seven days per week. Yes, he lacks some of the general legal background gained
24 at law school, however he is fully involved and immersed in all areas of many types of law
25 including learned treatises and thousands of Supreme Court cases from all jurisdictions;
26 HOWEVER, if Remington finds a relevant Supreme Court edict or teaching that is on or nearly on
27 point, he is fully qualified to both paraphrase it, comment on it in 1000 ways, and to fully and
28 properly copy it into his documents, including this one.
In its defense, said Reinholtsens state court has been very polite, diplomatic and almost
536
1 obsequious with his friendly tone while ignoring Remingtons every: motion request for almost a
2 year now, case citation and detailed lengthy memorandum about all of these related issues, with the
3 bottom line remaining the sad result just written above, for whatever the reason.
4 (3) In the Godfather film, the Mafia always resisted having their photographs taken and when
5 they were taken, the cameras used were generally smashed on the ground and the film was
6 removed.
7 Similarly here, Gans and the Mitchell firm have no photograph on the wall behind glass
8 depicting the officers of the RICO racket, as it is secret, totally underground, clandestine and
9 concealed not boasted about our broadcast, similar to a CIA spying or conventional double agent
10 operation.
11 Naturally, Gans, Brisso, Plotz, McBride know exactly what is going-on with the enterprise
12 24-7, and Lawrence is also apprised and updated daily of all charged time in one quarter (1/4) hour
13 increments, or less. Remington has seen how Gans and Brisso keep their time very specifically and
14 actually quite corruptly, because that was a litigation issue back in 2009. They do not show all
15 details, no summaries of the content of meetings that were held or what business transpired during
16 phone calls, just generalized statements of specific expenses and plenty of double billing, padding
17 of hours, etc. Essentially, they just want to get paid and are very experienced at keeping track of and
18 justifying the thousands of hours that they spend on all this. Therefore, realistically speaking, it is
19 likely and also known to Remington that Lawrence is deceived by a lot of these massive RICO
20 enterprise expenditures, much as most courts have been, because Gans is a master con-artist.
21 Thats what he does, and that is all that he knows, in order to partially succeed. Remington
22 has seen it firsthand for over nine years now. Remington very fully understands what Gans does,
23 remembers it, writes about it and is now complaining about it here.
24 As has been explained above, Remington even reported some of these Gans and Mitchell
25 firm gross financial irregularities to Lawrence, that he discovered in his exhaustive investigations of
26 defendants special motion billing statements, including substantial double billing, over-billing,
27 inflated hours and even charging for motion fees in other cases, etc. If Gans had attempted to do
28 any of that at any major private corporation Remington has ever worked for or within Remingtons
own Corporation and large businesses, Gans wouldve been immediately fired many years ago. His
537
1 handling of costs and payments and his failure to honestly account for same is clearly corruptAnd
2 during discovery we would anticipate that corruption is probably much broader than what we have
3 seen, and presumably extends into the tax arenas.
4 Basically, When Remington complained about Gans to Lawrence in 2009, got no response
5 from her, and whether the Mitchell firm has reformed their ways and gone straight and become
6 honest in their self-reporting of their hours spent on these cases, would be quite unlikely, however
7 thats not really Remingtons concern here, although we will be seeking extensive financial
8 information has related to these RICO allegations.
9 What we absolutely do know so far is that Gans deceives virtually all whom he comes in
10 contact with. He is very disappointing as a legitimate lawyer, but does excel at false logic,
11 mischaracterizations, and convincing people of the truth of his false facts, fake news and of such
12 frauds such as that black is white, or that Remington is the criminal bad guy here, and the poor
13 Mathsons are the victims and he (Gans) is merely doing his job to promote justice and in the
14 Mathsons suffering.
15 Being a world-class, or at least a Southern California-class con man, it is very likely that Gans
16 has Lawrence believing these cases are finally in their last month, and that this very expensive con-
17 game he plays with Lawrence, which has presumably taken place ever since at least 2012 bogus,
18 will soon end and not continue for another decade or more. It has not yet been discovered whether
19 Lawrence is fully knowledgeable about and involved in all the details of the enterprises corrupt,
20 misrepresented documents and litigation positions, such as his perjury-based 2011 federal
21 protective order and summary judgment motion, which he later reprised into his bogus and
22 frivolous collateral estoppel 2014 state court summary judgment motions which were flagrantly,
23 corruptly an entirely based upon his plagiarized, intentional, fraudulent, material
24 mischaracterizations of federal judge Vadas 2011 summary judgment motion ORDER. That first
25 2014 state collateral estoppel summary judgment motion, originally scheduled to be heard by Judge
26 Miles resulted in her being disqualified by Gans because she knows too much about the Mitchell
27 firms corruption, and Gans and Brisso in particular. That knowledge could have come alone from
28 her 2009 experiences in these cases, however undoubtably she has learned about plenty more
corrupt and derogatory information about Gans, Brisso and the Mitchell firm, since then because
538
1 she watches them, is very smart and because they just stupidly keep trying to con everyone in the
2 Humboldt County judicial system, as a matter of course. Somehow, said RICO defendants herein
3 get away with their fraud and abuse in Humboldt County Superior Court, and WHY all the judges
4 here (except for Judge Miles), let them get away with that is probably understood, but is slightly
5 beyond the scope here. Gans and Brissos RICO deceptions surprisingly work on 90% of these
6 local very unsophisticated Northcoast country people, and MOST of the judges also just weekly
7 acquiesce to it, Remington has noticed, so why stop doing a good thing? Remington and Judge
8 Miles are among the estimated 10% of Eurekans who dont buy Gans friendly, earnest and
9 forthright-appearing fraudulent deceptions, and Remington is counting on the fact that 60% or more
10 of the judges and jurors down south in the San Francisco area, will see through Gans rather
11 quickly, especially the judges, which would be more than enough.
12 Therefore, there are no overt officers in Gans enterprise, however like in the Army or
13 Marines, everyone on each side of the battle knows who their General is and who the officers and
14 soldiers are, within that organization. The enemy rarely knows and the UN or other outside parties
15 or forces do not have to know and probably dont know until they capture conclusive enemy
16 documents or until other believable facts are discovered at a later time. In this case, Remington has
17 been intimately involved with the RICO enterprise sufficiently to fully disclose it accurately,
18 however the final story and final organizational hierarchies within this enterprise will only be drawn
19 with absolute accuracy in several years of increased information. Fully probing this RICO
20 enterprise is not unlike unraveling all of the activities and exact command structure of the World
21 War II Japanese military organizations.
22 Obviously, if Remington knows and fully understands Gans Enterprises organization chart,
23 then they all doAlso, as needed. Watching John Mathson and Plotz, plus their 6-7 or so other
24 witnesses, sucking-up to Gans for about three hours for more than 110 days taught Remington a
25 lot about their interactions, lines of authority, who was paying whom and whether it was money or
26 general disdain or hate for Remington, whom none of them actually know, which was motivating
27 them.
28 Remington understands management and authority hierarchies as well as anyone. He has been
a CEO, corporate president and administrative associate in numerous large and small corporations
539
1 and other entities and of course has worked with hundreds of them, at all levels. For more than 40
2 years, Remington has employed thousands of employees on his own, in his own businesses and
3 under his direct management control at major corporations such as the Gillette Corporation,
4 Research Analysis Corporation, Bionetics Corporation, the Maryland National Capital Park and
5 Planning Commission, Melpar, Operations Research Incorporated and the County of Fairfax to name
6 only some of them. In other words, Remington knows a little bit about management and how peons,
7 soldiers and top administrative assistants relate to CEOs, presidents and/or enterprise chieftains,
8 generals, bosses and/or dons. Remington used to recruit and mostly just screen out literally
9 hundreds of generals and admirals, PER WEEK, while working at Research Analysis Corporation,
10 for example, which was the counterpart of the RAND Corporation for the US Army, in the late
11 1960s. Remingtons brother similarly has an aptitude in this area and is a full university Professor
12 of Business and teaches these things, if Remington ever had any doubts or questions, which he
13 never did.
14 (4) Obviously, Gans racketeering enterprise has no directors or Board of Directors
15 either. Several of the loose affiliation of small and large associated businesses which comprise the
16 main working portion of this enterprise, have directors, their business is not necessarily secret, nor is
17 most of it public either. All organizations maintain various levels of security and secrecy from their
18 competitors, the public their regulators, etc, but less so than a criminal organization, rather
19 obviously.
20 Therefore, some of these RICO enterprises component group of loose associated entities do
21 have directors, such as Allied, SHN, Humboldt County, in some sense, inconceivably even RAO,
22 Inc, however that is irrelevant and Gans enterprise does not have directors beyond the leadership
23 nucleus described.
24 The enterprise members do meet in very small groups or individually with Gans and/or his
25 lieutenants and supervisors from the Mitchell firm, to get their orders, read and discuss their
26 numerous reports, and if they get paid promptly they are stoked, and are thereafter in the
27 organization for life until they are no longer needed or dont get paid. Until discovery proves
28 otherwise, Remington assumes and infers, from his 10 years of exposure to the present RICO
enterprise and its precursors and roots involving some of the present enterprise, which is involved
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1 primarily in a cover-up as explained, THAT ALL these enterprise members are all very well and
2 timely paid. These RICO members all our grossly overpaid and we will prove it trial that they all
3 make much more money than they can get anywhere else in the Eureka marketplace. Since Gans and
4 Allied (and RAOs still unknown insurer that presently is believed to finance Kluck) have literally
5 unlimited funds to defeat Remington with here, money is no problem for this RICO enterprise
6 which keeps growing by approximately 3-10 members per year. This particular RICO enterprise
7 will not endure forever, because its purpose and objectives are specifically to crush Remington.
8 Therefore, whenever that occurs or if these cases ever and, the RICO enterprise will rapidly dissolve
9 and instantly disappear similar to popping the large overstretched balloon. Depending on the exact
10 details, said RICO enterprise would at a minimum pretty-much become invisible, latent or be at least
11 suspended until the next Remington case or environmental land-use case involving Remington on
12 one side or the other, comes along. At that time, the majority of these present RICO members will
13 quickly be able to reform into a similar network analogous to what they have now, but just happily
14 lacking the Mathson and RAO- affiliated friends and associates, which now form about half of the
15 organization. In any case, when Remington is gone from the scene, and Gans needs another RICO
16 enterprise to win his next real estate or contamination oriented case, he has a ready-made nucleus
17 and foundation for his next enterprise, because all of the key members will remain. Remington will
18 now forgo the abstract consideration of whether this RICO organization would still exist battling
19 Remington at some other location, or from perhaps the other side of his property which did not
20 involve Mathson or RAO. Although quite interesting philosophically, for now Remington believes
21 he has accurately explained the structure of the present RICO enterprise at issue in this specific case
22 and believes that this enterprise will probably continue until either Remington or Gans dies, however
23 neither of those contingencies would automatically end this enterprise, and it is perfectly likely and
24 logical that it will continue until no Remington still owns the property south of the Mathsons. Again,
25 why that would be as projected out 10 or 100 years from now is beyond the scope here, but it may
26 well be an issue far-out into the future here, because of the continuing nature of the contamination
27 emanating from Mathsons property without any apparent end to it.
28 Continuing as to the structure of Gans RICO racketeering enterprise and whether it would
continue after Remingtons death or after his heirs have all abandoned Westgate Drive, it is of
541
1 academic interest to speculate on whether this RICO enterprise would continue on into Gans next
2 corrupt contamination case against someone else. As defined above, the answer to that is NO and
3 Gans would have to form a new RICO enterprise against a different plaintiff, but otherwise it might
4 have all nearly identical members, corrupt practices, the same methods and procedures and virtually
5 everything else might be identical, however it would be a new and different RICO enterprise which
6 would have to be sued independently by the next target of Gans next RICO conspiracy. Although
7 the perjuring Mathson-RAO coached witnesses are crucial in this enterprise, Gans is highly
8 competent at what he does and will easily and quickly develop some new key perjurers to fill in
9 any gaps in his next case, most probably. That is one reason why Gans needs to be stopped here.
10 Although brazen and courageous psychopaths, that feel little to no fear, such as John Mathson
11 and Skillings, are very valuable to Gans and possibly versatile enough to commit criminal acts in
12 Gans next unethically litigated cases, it is more likely that Gans will disassociate himself from
13 ALL his former loyal perjurers and try to start fresh with a new batch. That would appear to be
14 safer, more directly applicable to the subject matter and parties in his next litigation, especially in a
15 RICO enterprise such as this one, where the first member that crumbles, and feels some fear or
16 empathy or decides that prison just wouldnt work for them for very long, will probably lead to the
17 destruction of the entire enterprise like a sand castle being swept-away by a large wave, or two.
18 Very obviously, Gans has a MUCH lower probability of getting caught if he dissolves this
19 enterprise 100% after it accomplishes its objectives, so that everyone can forget all this and Gans
20 can start a new house of cards or sandcastle on a better foundation, or farther from the surf, next
21 time. Possibly thats why he went to Farallon, and Hillyard, all the way up in Portland, for his next
22 environmental expert because he wants to start fresh with a new young uncorrupted engineer, has
23 not yet learned that Gans is a crook that writes the script for his environmental experts. Everyone
24 in Eureka knows that, so Gans had to go about 800 miles away to find someone that did not know
25 that Gans was a criminal by reputation in this area. Gans can always come back to Blue Rock and
26 that generally incompetent bunch in several years after they have forgotten their bad experiences in
27 this case, and IF all have clearly avoided punishment here, which is presently unlikely and
28 completely absurd if the Blue Rock group proceeds into a federal environmental trial next.

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1 On the other hand, if no one does any prison time here Gans does have a very valuable,
2 enviable clandestine conspiratorial bunch to use in his next cases: including all his Superior Court
3 spies, clerks, saboteurs and judges (if any) who would all be invaluable for the next one. Also,
4 Pulley has acquitted himself well here, and along with the other Health Department insiders he
5 has, who will all be beyond invaluable in many, if not most, types of cases that the Mitchell firm
6 gets involved in. Without listing them all here now, Gans has a great nucleus to start from next time.
7 Gans also has the extremely important advantage of all of the other Mitchell firm attorneys for
8 charter members of this enterprise and quite possibly have other enterprises going right now which
9 we dont know about, and are also somewhat irrelevant. An enterprise like the present one is
10 really sweet with all those courthouse saboteurs and confidants, and when it is purring-along
11 without any discovery, recriminations or interference from anyone and while it is also winning and
12 earning hundreds of thousands of ostensibly honestly earned legal dollars, when in cold reality
13 the money that Gans is now making is no more honest than Don Corleones protection, bribery,
14 gambling extortion and murder rackets.
15 When the county or federal criminal authorities do eventually get interested here, which will
16 hopefully be during Remingtons lifetime, they are expected to discover several other past and
17 present RICO rackets also being carried out by the Mitchell firm and being financed by Lawrence
18 or other insurers. Gans appears to only work for insurers hourly wages and obviously there are
19 many other corrupt natural progressions for this sort of RICO enterprise such as staging accidents,
20 arsons or other injuries or casualties under homeowners policies. Quite possibly Gans present
21 perjurers that he now has on-the-hook may now be intimidated, extorted, BLACKMAILED or
22 just otherwise encouraged for good old American profit to help Gans and the Mitchell firm in
23 other corrupt cases. For someone like Gans, there is no real limitation (including the sky) and
24 Remington would be very surprised now if criminal authorities could not find evidence now that
25 this little Remington case is likely only the tip of the iceberg for what the Mitchell firm would
26 be capable of contemplating and executing, now that theyve got the hang of illegal activity, and
27 found that they love it, and get just as much satisfaction from their unlawful racketeering
28 monetary gains is from getting it from honest activity.

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1 Presumably the authorities will make an exhaustive search of past, present and continuing
2 fraud or related damages cases perpetrated by or assisted by the legend Mitchell firm criminals,
3 because with the kind of money involved here it seems unlikely that this is an isolated case. Gans
4 and Brisso are just too good at it, too relaxed, too experienced and smooth, and love tricking judges
5 and winning motions with mostly deception plus an occasional partially honest fact, too much just
6 to give this all up. Plus, as above, their courtroom saboteurs, contacts and/or other influences are
7 just much too valuable, powerful and important to use in just this one case.
8 Additionally, it should be mentioned that Remington alleges that defendants motion
9 documents are as much as 50-75% straight, ordinary and largely truthful.
10 A psychopath does not have to kill everything in its path, when a confident smile and a few
11 honest facts can often win the debate or decision, so overkill is usually not even required except
12 apparently at trials here. In these cases, Gans has needed illicit deception and corruption here for
13 years to have any chance at all.
14 6 (d). State whether any defendants are associated with the alleged enterprise, and
15 if so, how. ALL are associated with it, but also SEPARATE from it as discussed above.
16 (1) By definitions, all TWELVE, (12) presently named-defendants, with some more to soon
17 follow rather obviously, are associated with the enterprise and form its operative nucleus, brain
18 trust and/or primary nervous system and backbone. Their association with Gans, with each other
19 and how they conspiratorially associate and act against Remington including the specific damages
20 which they are alleged to have caused have all been thoroughly explained above and in these
21 associated documents; however, much more remains to be discovered and also eventually the
22 additional information which we already know about these defendants will be either added to these
23 documents or presented at the next trial.
24 The other 25 or so presently unnamed associates and present enterprise members are also
25 associated with the alleged enterprise and cumulatively all 35-40 form the totality of the enterprise.
26 Those 35-40 may have secretaries, assistants, close personal confidants or use other outside services
27 such as technicians, accountants and repair people, etc. which does not necessarily make the latter
28 group part of the enterprise. The actual and true enterprise stops somewhere, as do its members
who are taking reasonable actions to support and achieve the enterprises objectives. A gas attendant
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1 that fills an enterprise members pickup truck or a grocery store checkout clerk that sells Gans
2 groceries or essentially anything is not a member of the enterprise per se. They could be potentially
3 if they helped Mathson, and personally vandalized Remingtons fences or went to court and
4 committed perjury on Gans behalf, however some sort of very direct action in the legal system, and
5 against Remington, such as doing bogus testing for the lawsuit, writing false or partially true sworn
6 documents, or testifying deceptively or dishonestly in the lawsuit, is about the minimum threshold
7 for full enterprise membership, or possibly just association in the case of a witness that testified
8 substantially or entirely truthfully for Gans, such as Pulley, addressed next. Whereas, actual
9 criminal predicate acts are required to advance from enterprise membership or association into
10 actual actionable RICO racketeering enterprise membership, or genuine RICO defendant stature.
11 (2) Pulley. Furthermore, some sort of illicit, deceptive or at least semi-corrupt behavior or
12 activity would be necessary to be implicated as part of this RICO enterprise. Mr. Pulley is a good
13 example of someone whos right on the borderline. He made a very inaccurate and deceptive
14 diagram on one of his maps but he acknowledged that he just was following orders and that it was
15 Mathson and Gans that gave him directions. He has not lied about it yet and he may or may not be
16 part of the enterprise, which remains to be seen. Today, he is just an ordinary surveyor who is not
17 a named defendant, and is merely loosely associated with, and being paid by Gans which does not
18 intrinsically or by definition make him an enterprise member. Gans uses lots of honest, ordinary
19 copying, exhibit-making or photographic services, for example; or, he might buy a birthday cake for
20 one of his associates, all of which activities would be legal and none of the workers involved with
21 those named activities would be corrupt or any kind of illicit member or associate of Gans
22 complaint-of RICO enterprise.
23 Actual Membership here, requires some sort of willing and knowing corruption, intended to
24 further the enterprises objectives against Remington in an illicit or illegal manner. Honest
25 testimony against Remington would be outside of any RICO enterprises implacability, most likely.
26 Pulley has not yet said anything detrimental to or about Remington or made any known corrupt or
27 dishonest representations in writing or in trial testimony and therefore until that changes Pulley
28 would arguably not be an enterprise member to potentially go to prison when the whole

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1 enterprise collapses like a house of cards. Very few of those named herein by name however have
2 the interesting and rather unique status that Pulley maintains so far, except for Hubbard.
3 (3) Hubbard. Another interesting borderline example is Jack Hubbard of Weaverville who
4 did a 2008 survey for Mathson and Gans which Remington was initially unhappy about; however,
5 when Hubbard decently and pleasantly agreed to provide Remington with copies of all his mapping
6 and surveying work, regarding the location of the property line, the flagged stakes and the agreed
7 fence, a fairly valuable service, and also even tried to briefly and wisely mediate the dispute, that
8 endeared him to Remington.
9 Those ethical, honest and human acts by Hubbard caused Gans to immediately fire him
10 when he heard about it because Gans knew that Hubbard would not perjure himself or specifically
11 attack Remington the way an enterprise member, or the unethical precursors thereto were required
12 to do, even as far back as 2008. Therefore, Hubbard is definitely not a RICO enterprise member
13 today, and in fact he will likely be called as a Remington witness because it was Hubbard that
14 prophetically said the only people who are going to benefit from these lawsuits are the attorneys,
15 and that was so true, accurate and prophetic that it is tempting to call him in as a wise witness to
16 instruct the jury generally and possibly to tell the real truth about Mathson and Gans, and what
17 he would be willing to testify to about what Gans wanted him to lie about. A Remington witness or
18 a former Gans witness or former enterprise associate or employee, etc that goes straight, decides
19 to testify honestly and therefore eventually testifies in favor of Remington and against the RICO
20 enterprise, would by definition not be in the enterprise, perhaps be fully or partially exonerated or
21 even potentially forgiven for minor federal predicate acts, and therefore might very well become
22 exempt from federal penalties.
23 (4) Other. Today there are 12 -named defendants listed, which number has varied up or down
24 by one or two over the last several months, and often involved Morgan Randall, for example, who
25 today is right on the edge of Gans RICO conspiracy, but discovery is needed to fully clarify his
26 role in the actual enterprise as is the scope of his anticipated false testimony. Randall and Gans have
27 refused to disclose the content of his contamination trial testimony, but we will take his deposition
28 shortly in the federal case and also evaluate what he has been scripted to testify about in the

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1 contamination case, where he is a named defendant here, for the reasons explained in all of these
2 documents, in some detail.
3 There are several other names, several of which are very obvious, which are right on the
4 very edge of complicity here, and it is a subjective matter which involves many variables
5 including economy, fairness, solid provable, present evidence, inferred future evidence and clear
6 criminal intent, or possible lack thereof. Discovery is expected to add several names, and subtract
7 from the number of DOE defendants, such as hopefully we will get the name of one file room spy
8 from Gans, Plotzs, McBrides or Joy Mathsons depositions. Hopefully, discovery will also
9 enable us to possibly subtract one or two names, from the named or nearly named RICO
10 defendants.
11 A Superior Court spy, saboteur or otherwise unethical law violator in any respect, such as are
12 alleged in the courthouse, if discovered or if even supported with any positive evidence at all, will
13 immediately jump into the top 3-5 named RICO defendants as related to 2012-16 state and federal
14 predicate acts.
15 (5) How are the above TWELVE (12) named-defendants associated with the
16 enterprise? [Continuation of question 6 (d).]
17 Although the answer to that question has been repetitively explained throughout all of these
18 documents, in the interest of thoroughness, possible additional clarity, full understanding and
19 disclosure, Remington will briefly respond specifically (again) to that exact question.
20 A-1: Gans runs the enterprise 100% personally and operates through several subordinates
21 and he has been more than adequately covered above. See A-12 below for the additionally-named
22 four (4) other Mitchell firm RICO enterprise members;
23 A-2: Linda Lawrence is believed to still be the primary financier and representative of Allied
24 insurance in this RICO enterprise, but if we learn that she has been replaced, or hopefully just fired,
25 then we will direct suitable initial written discovery to her replacement. Apparently she took over
26 under Mathsons long-time homeowners insurance policy and has been apparently involved since at
27 least 2007. On or about February 10, 2017 at the last DR140426 hearing, Remington submitted a
28 fairly lengthy status conference report, but also concurred with the other defendants that another
stay of 60-days would be wise due to the imminent filing of this case. At the next stage hearing,
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1 probably in April, Remington expects to request that the state stay in the above-referenced case be
2 lifted, so that needed discovery can seriously commence against RAO, Mathson and the others that
3 Kluck represents on behalf of RAOs unknown business insurer. At that time said insurer can expect
4 to begin paying Kluck the kind of rapidly increasing bills which Allied has now paid for about 10
5 years, especially when activities in this case begin in San Francisco and supporting depositions and
6 written discovery begin both here in the federal case and also in the aforementioned state case
7 where discovery has not even begun yet. It still appears to Remington that maybe just cleaning-up
8 Remingtons land might be superior to another 10-years of legal battles resulting in the same thing
9 multiplied by 2-3.
10 A-3: John Mathson (along with his angry wife Joy) are the main defendants along with
11 RAO in the state cases going way back to the 1998 initial encroaching trespasses. Joy Mathson is
12 named in the contamination portion of this federal lawsuit, but is not presently named in the RICO
13 case because she hasnt done anything federally corrupt here yet that we know about. She was ready
14 to commit perjury in the SOL trial, but neither Gans nor Remington called her for different reasons.
15 She is however considered briefly at A-9 below.
16 Historically, as is well-established in the nearly nine-year litigation record, Remington
17 discovered defendants contaminating trespasses in 2006 and then investigated and considered
18 whether to file litigation for the next 2 years. Remington filed suit in DR 080678 in July 2008,
19 one Court day after the Mathsons sued Remington for visual nuisance and for Remington to
20 move a simple fence a few feet, which had previously already been agreed to informally by the
21 originally friendly neighbors.
22 From the inception, Gans intended to break Remington easily, using an aggressive scorched-
23 earth litigation policy beginning in 2007, which has been perpetrated to date, despite about a dozen
24 settlement attempts, 90% originating from Remington, and even at least two actual settlements in
25 principle, which Gans sabotaged at his earliest convenience, in each case. The Mathsons are
26 Remingtons adjacent and northern landowners who illicitly imported, in an illegal for-profit
27 hazardous residential dumping scheme with RAO, approximately 4000 yd. of contaminated debris
28 and concealed at least 20% of that debris on Remingtons land without his knowledge or consent.

548
1 This court may not, and need not understand the Mathsons central role in these litigations for
2 approximately eight years, but all named defendants here do, as more than 20,000 pages and three
3 earlier cases cover the Mathsons and their crucial role in these cases. The Mathsons since 2007
4 have never been more than mere puppets for Gans to accomplish his previously described,
5 disreputable purposes, and mostly to bring himself in substantial legal fees, which he has brilliantly
6 succeeded in doing. The word Mathson probably appears 2-10 times per page in those above 20,000
7 pages.
8 Finally, as alluded to above, Joy Mathson has not had an obvious or known active role in this
9 RICO enterprise during the last four years, and the fact that she was well-prepared and ready to do
10 so in August 2016 does not alter that fact. Therefore, it is going to be significant to get her
11 deposition early-on in this case, to see if shes fully committed to support Gans criminal RICO
12 enterprise and is thus going to commit federal perjury here. Imprisonable federal perjury
13 testimony and resulting charges will immediately occur if she attempts to regurgitate the script
14 Gans wrote for her in 2016, which was intended to support the other subordinating perjurious state
15 trial witnesses, named throughout these documents. Repeating all that provable perjury in a federal
16 case will be very serious as alleged, and presumably explained to defendants hereby criminal
17 investigators, because what Remington says or thinks is not especially important. This RICO
18 statement and cause of action is merely Remingtons interpretation of what will happen under
19 obvious and clear federal law if Gans well-established cycle of perjury in the state case continues
20 here. Remington certainly hopes that Joy Mathson will attempt to be honest as she attempted to be
21 in her 2010 deposition, but doubts that she is prudent enough to back off from this while she still
22 ahead. Coaching perjury in his trial witnesses is Gans basic nature; He cant help it or control it,
23 so presumably the inevitable will eventually occur here, as regards Joy Mathson, who was already
24 to go in August 2016, as described.
25 A-4, RAO Construction, Inc. and Olson. President Rich Olson has been sued here and in state
26 court, as has his ruthless and tough 20+ year loyal employee Kyle Skillings also, see A-5, which
27 follows. As further specified above, RAO Co. Inc or whatever its exact business name is is also
28 being sued under this RICO action. Remington does not know Olson and has never knowingly
met him in the last 40 years, although he may have unsuccessfully bid the 832 Westgate foundation.
549
1 On the other hand, Skillings has had a high profile in the state cases since about 2011 and was
2 cross-examined for about 30 minutes by Remington in the August 2016 SOL trial. Olson was the
3 central demonic and criminal mastermind behind the illegal, highly profitable, residential toxic
4 waste dump established on Mathsons land and Remingtons in 1998. So far, however he has made
5 no appearances in any of these cases and his attorney Kluck has sat in on hearings but really hasnt
6 participated in substance as to any issue so far. Olson is crucial in the state contamination cases and
7 presumably he and his attorney will become important in this case once they are deposed or called
8 as trial witnesses. If they tell the truth about any of these issues, in any of these cases, they will
9 incriminate themselves and be liable for criminal state and county charges, so how they get out of
10 all that without committing any violence against Remington, remains to be seen.
11 If anyone mentioned in this RICO statement deserves investigation by criminal or civil
12 investigatory services, Olson would appear to be the place to start, but simultaneously with Gans of
13 course. Therefore, Olson is in a somewhat strange and enigmatic position today in this RICO
14 enterprise. He and Skillings were intimately involved since 2012- 13 and the extortion, intimidation
15 and blackmail of Bob Figas, however no other specific crimes are presently known or provable.
16 Intensive discovery is needed from the RAO group, and since they were the original criminal
17 perpetrators of this whole problem starting in 1998, Remington believes that eventually he has the
18 most to fear from them and that before this RICO case gets into a federal jury trial Olson and
19 Skillings will have committed a variety of additional predicate acts in order to avoid opening their
20 mouths about any of this during federal discovery. Anything they might say about any issue
21 mentioned or discussed in any of these accompanying documents is believed to half to be highly
22 incriminating.
23 A-5, Kyle Skillings. Skillings is now quite well-known in these litigations. Presently he is the
24 only representative of RAO construction and Olson that has been active here. His state trial
25 testimony indicated that he is going to pretend that he was not affiliated with RAO but just did
26 Mathson a series of viable favors over three or four months in 1998 by working evenings and
27 weekends to do a $150,000 job. Skillings apparently thinks that Remington and juries are stupid
28 and that we are going to believe that a cold, cutthroated entrepreneur like Olson just provided all of
his trucks, loaders, excavators, skilled employees and other equipment to the Mathsons free of
550
1 charge for many months and then absorbed the estimated $150,000 equipment, insurance,
2 maintenance and servicing, personnel and overhead costs, etc himself, as an act of charity for his
3 friends the Mathsons, whom he barely knew then, if at all. We dont need to prelude the RAO
4 depositions or several days of related trial testimony, however suffice it to say here for this court,
5 that happily Remington is a foremost Northcoast expert on trucking and excavation operations and
6 owned and operated his own such company, with many of the same loaders, semi and end-dump
7 tractor and trailers, supporting equipment, skilled personnel, insurance, overhead and continuous
8 mechanical problems, which RAO did in that same timeframe. Simply put here, rental companies
9 charge $500-1000 a day for that type of heavy and break-down prone equipment or about $100 per
10 hour for any of it operated. Those costs add-up to very high amounts, over a period of 3-4 months,
11 and no one provides such services free and in fact a high cash flow is ordinarily required for even a
12 major construction Corporation operate properly. In this case, the evidence indicates that RAO
13 would have had to have cash inflows of a minimum of $100,000 per month and probably 2-3 times
14 that in some or most months.
15 On the other hand, Skillings is planning to lie and misrepresent about all of that and attempt
16 to argue that RAO had no costs here and everything Mathson received, including about 400 10-yard
17 dump loads of of toxic debris, which the original owners of said debris would have paid OLSON
18 VERY dearly to get rid of, was free and just the act of a friend (Skillings) doing another friend (the
19 Mathsons) a simple and small favor on weekends. RAOs financial records, when discovered, will
20 show that neither Mathson nor Skillings paid one penny for 1 gallon of diesel or for any repairs or
21 maintenance for any of that excellent RAO equipment for 3-6 months in 1998.
22 Fortunately, Remington knows now from about an hour of cross-examination, that Skillings
23 lies completely, freely, expertly and without apparent guilt or conscience, while under oath, about
24 almost everything. That was entirely proven in the August 2016 SOL trial. Remington has evidence
25 to prove that and in any next state or federal trial he will easily do so using the August 2016
26 transcript and accompaniment with his entirely incriminating in impeaching 2003 photographs..
27 Inexplicably, Judge Reinholtsen did not allow any use of those photos for impeachment or for
28 anything else, however, Gans and defendants are beyond-worried about those photos, as theyve
seen them, verified their authenticity and they will obviously be admissible in any future state or
551
1 federal trial to absolutely and conclusively refute Skillings, Olson and also their other perjurers,
2 using other also unadmitted evidence.
3 Skillings is also tough and mean and when he left the August 2016 witness stand after his
4 cross-examination, his icy, inhuman demeanor and attitude, that scared the hardened logging boss
5 Figas in 2012-13, as explained above, was apparent.
6 In fact, as he left the witness stand, and walked about 7-feet away from Remington who was
7 then standing at the podium, Remington clearly read in his eyes, threatening body language and the
8 inaudible movement of his lips as he walked out of the courtroom: Keep this up Remington and
9 Ill kill you, or something similarly violent along those lines. We will explore that further at his
10 next deposition, but meanwhile his likely future retributionatory actions are of great concern,
11 especially after this document is file, and he is named as a defendant for his direct and salient
12 involvement here. He may well be desperate, because he has committed serial trial perjury already
13 in the state case, under Gans specific direction and believed protection, but now has no apparent
14 legitimate way out of that now. Skillings clearly speaks for Olson, Mathson and Gans, but has the
15 balls to perform the mafia enforcers role here such as Luca Brassi, against Remington, Figas and
16 anyone else that makes any progress towards discovering RAOs buried secrets. Other than Gans,
17 no one concerns Remington more than Skillings, who appears to be possibly emerging as the main
18 protagonist here.
19 Specifically, Skillings to date has (1.-6.):
20 1. Operated RAOs huge loader, excavator, cat and other equipment for many months in 1998,
21 carefully and intentionally sorting and then placing and burying more than 600 yd. of asbestos,
22 lead, gas station remediation hydrocarbon-saturated soils, rubber, asphalt and many hazardous and
23 carcinogenic other materials, on and within Remingtons land. Said Remingtons land was very
24 steep and contiguous to the South, was heavily Redwooded with a major Creek Gorge 30-50 feet
25 below and only 10-20 yards away horizontally to the south. VERY considerable defendants debris,
26 something like 2 million pounds worth in fact, was very intentionally rolled rapidly and inexorably
27 down the almost 60 bank at that spot into that creek, just as predictably, and inevitably as overly
28 ripe apples falling off a tree, onto the ground;

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1 2. Skillings also flatly lied in his Gans written in scripted 2011 declaration, read in the August
2 2016 trial, and then lied about further in court in 2016, about nonexistent discussions with
3 Remington about fill or anything else in 1998. Remington was nowhere near Mathsons property in
4 1998, and therefore never spoke to any equipment operator of any kind over there, until at least
5 2004-5. Remington does not recall any specific conversation with Skillings up by Westgate Drive
6 ever, however if there ever was any brief contact with anyone on Mathsons land by Remington, it
7 would have had to be around summer 2005, when Remington was developing that area and able to
8 get there at all. In August 2005, Remingtons records prove that he was working right along the
9 Mathson-Remington boundary, within 50 feet of Westgate Drive, planting trees according to
10 detailed plans, and he did fill-in a small shallow area up in that area with his own vast surpluses of
11 dirt, so that he could easily walk into the present site of irrigation tank A.
12 Remington did not need any additional dirt from Mathson, Skillings or anyone else but that
13 whole issue can be taken up again at the next deposition were the 2003 photographs will be featured
14 as well as photographs from 2005, to see if Skillings is able to summon any kind of truth at all from
15 his clear, Gans-scripted memories.
16 3. As documented throughout, Skillings severely scared, extorted and blackmailed Figas
17 in late 2012 and January-February 2013, when Figas repeatedly considered returning to
18 Remingtons land, he said, but never did.
19 4. Skillings and Olson allegedly also extorted Wayne Marsh, Remingtons next excavator
20 operator and possible remediation consultant and expert, giving him the same kind of scary
21 treatment they gave Figas about two years earlier. The details of what happened need to be
22 discovered, however in November 2015 Wayne Marsh solemnly assured Remington that he would
23 show-up on a Saturday afternoon right before about 6-inches of rains, after being specifically
24 recommended by Figas. The day before, Remington walked the job and discussed it with Marsh in
25 detail for about an hour and everything was harmoniously 100% set-up, but RAO somehow got
26 involved, because Remington wrote about it and tipped-off Gans in various motion documents ,and
27 the next thing was that Marsh was intimidated into not doing the job. Since Figas was the one who
28 had suggested Marsh in the first place, discovery may also show that Olson or Skillings heard about

553
1 Marsh somehow through Figas, because he was extorted, in any event, and never has showed-up
2 since.
3 Its been that way for years, RAO is deadly afraid of anyone excavating anywhere near, even
4 within 400 feet of their dump and burial grounds, as explained in detail above.
5 5. In August 2016, Skillings reversed his sworn trial testimony, which was fully rebutted by
6 Remingtons 15+ 2003 photographs. After meeting further with Gans to be coached to make his
7 testimony consistent with Gans other previously perjuring witnesses, Skillings completely changed
8 his testimony while under oath on the witness stand. His original declaration had been perjured,
9 however in 2016 Skillings suddenly and imaginatively went from having one meeting with
10 Remington were Remington purportedly requested more fill be pushed over onto his land, to at least
11 TWO such imaginary meetings in 1998. There never was even one such meeting in 1998, or any
12 other time, and inferentially therefore there were not TWO either! As discussed above, Remington
13 never could reasonably even get over to the Mathson line at issue here, across the ravine and
14 through a horrible field of nettles, and never considered, discussed or planned anything about
15 filling-in the shallow draw at the northern edge of his property until summer 2005, when he put in
16 Tank A, as just discussed above. At that time Remington did need access across the 6-8 foot deep
17 narrow, but treacherous, ravine in that area, where he ultimately used his own approximately 20 yd.
18 of dirt from his own adjacent stockpiles of several hundred yards of surplus dirt which was in his
19 way.
20 6. Skillings intimidation and threats to Remington. Also as above, in August 2016 Skillings
21 lied on the stand as described, and then when he left the witness stand he gave Remington an
22 intense series of very seriously dirty, dagger -like looks, threatening mannerisms and inaudibly
23 mouthed something about killing, harming or doing violence of some sort to Remington, if the
24 latter did not back-off with these photos and truth stuff. That incident occurred over
25 proximately 10 seconds as he very slowly and deliberately dragged himself out of the witness
26 chair to focus all attention on himself, and then quite menacingly left the courtroom, only about 7-
27 feet away from the lectern, where Remington was standing and watching him intently, which
28 interest was returned by Skillings as explained.

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1 Olson is really the key figure here that Skillings merely works for. We need a lot of discovery
2 from Olson, especially which should be able to start imminently when the stay in DR140426 is
3 lifted. The exact relationship and dynamics between Skillings and Olson is presently unknown.
4 A-6, Boyd Davis, was the City of Eurekas Public Works Director from 1996-2000. He now
5 appears to be long gone, so Cyndey Day-Wilson has been served here is the City Attorney. The city
6 is an important new named DOE defendant in the contamination cases, but is not presently
7 believed to be involved in Gans RICO enterprise.
8 Davis and The City are now NOT named (yet) in the RICO enterprise.
9 But, that could change rapidly when they call Gans to find-out what is going-on here because
10 the asbestos pipe allegations described below are probably and presumably a complete surprise to
11 the present city attorney.
12 Remingtons belated 2015 investigations as to the source of the large quantity of asbestos pipe
13 dumped on his land in 1998, which Mathson swore in 2010 came from a water pipe removal
14 project over by the golf course, led Remington initially to the HCWD. However, the directing
15 engineer of the HCWD, whom Remington has worked with and known for years on a variety of
16 water issues, told Remington unequivocally that they do not control that waterline and did not
17 remove any asbestos from there, but rather it was the City of Eurekas line and they did
18 replace it in 1998.
19 Discovery is expected to immediately prove that Rich Olson was the low bidder on that
20 project and probably Mr. Davis expected REO to use their monetary payment lawfully dispose of
21 the asbestos pipes properly and not on Remingtons land. However, we dont now know all that for
22 sure and meanwhile the city of Eureka bears some responsibility for RAOs criminal actions,
23 unless their contract, intent, knowledge and other numerous relevant factors somehow exonerate
24 them. Well see during discovery.
25 Meanwhile, hopefully they will not fall into the Gans enterprise trap itself, or become
26 transfixed under the spill of Gans corrupt treachery, misrepresentations and mischaracterizations
27 of all details of these cases now. If the city wants further information or clarification about any of
28 this, they might be well-served to just call Remington on the telephone and discuss it with him, or
preferably do so by email, on the written record.
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1 A-7, Jon Kishpaugh is an important Gans soldier, daily Mathson confidant, drinking buddy,
2 fellow dumper and doper, saboteur and long time close friend of the Mathsons since about 1994.
3 Kishpaugh lives essentially diagonally across the street from the Mathsons and has been Mathsons
4 apparent best friend for over 20 years. Their house is now in foreclosure, FORECLOSED and
5 purchased by someone else, which probably explains why Gans August 2016 high-priced
6 payments for his perjured testimony (a bribe in every day parlance) was so badly needed. What
7 exact amount of money he was paid will be discovered, because since Kishpaughs time is worth
8 less than $5-10/hour, since he is essentially useless as any kind of worker, unemployed, probably
9 disabled, usually drug-impaired, as questionable mental state ability and is clearly unemployable in
10 the honest marketplace, in other words, whatever he was paid was excessive and amounted to a
11 bribe.
12 Kishpaugh dumped huge amounts of debris on Remingtons land in his upper gorge for
13 years and then eventually was caught doing it after he broke down fences and disregarded no
14 trespassing signs to do it around 2005. At that time he was turned-in by his friend Joy
15 Mathson, before she publicly and overtly turned-against Remington forever. Joy Mathson gave
16 Remington irrefutable evidence of what to look for on Kishpaughs property which proved that he
17 had been the sought after dumper, and then Kishpaugh lied blatantly with a straight face to
18 Remington, when confronted and the relationship has never been the same since.
19 Under duress at the SOL trial, his every nervous word coming from his mouth was a potential
20 lie, followed by a little nervous laugh, which often confirmed it. Under Gans direct
21 examination, he was loving it, testifying falsely against his enemy Remington and hopefully
22 benefiting his good friend John Mathson so, as a result, he went very far-off of Gans written
23 script with this testimony. If he does that during his federal deposition in the contamination
24 portion of this lawsuit, he will get into deep trouble quickly.
25 He was supposed to just simply swear that he did see Remington talking to Mathson in
26 1998, which was false, and then get off of their and leave. However, he was enjoying himself so
27 much during his cross that he improvised, and went four-beyond his direct, when questioned, and
28 said: Yeah, I saw you there talking to Mathson a couple of times. That lie was triply false,
since Remington was 100% occupied on other matters throughout the 1980s, 90s and until 2004-6.
556
1 Remington highlighted that gross enhancement and embellishment of his original testimony to the
2 jury and the court, however no one was impressed by the truth, and hence Gans perjuries
3 overwhelmingly prevailed again.
4 As partially explained above, Kishpaugh took out his various angers at Remington in the
5 mid-2000s, when Remington permanently blocked his major dumping of garbage and organic
6 debris into his ravine, which had occurred several times per week for many years, saving
7 Kishpaugh at least $1000 of dumping and garbage pickup fees. When Remington eventually made
8 his fence impregnable to the local dumpers, including Kishpaugh, the latter took to abusively and
9 antagonistically dumping his debris right along Westgate Drive, up against and into Remingtons
10 huge 500-foot long hedge. Remington eventually used a backhoe several times to remove that
11 debris, but Kishpaugh persisted for several years, but eventually must have been shut-down by the
12 county, because it was ultimately their right-of-way.
13 Kishpaugh has been in and out as a named RICO defendant, and currently is
14 OUT but will immediately JUMP BACK IN, when he responds to his first Federal
15 Discovery request consistently with his perjurious State trial testimony, which he CANNOT
16 be implicated for here in this complaint, YET. In other words, we dont yet have two provable
17 federal predicate acts yet against either Kishpaugh, but we are not giving-up quite yet on that issue.
18 A-8, Morgan Randall was a former very young neighbor who rented a small house across the
19 street from Remingtons residence and estate at 832 Westgate Drive for a couple years, back in
20 approximately 1985-90. Remington never knew him, but he did have a young wife and two very
21 young children at that time.
22 Randalls odd relationship to Remington in these lawsuits has been discussed above and in
23 the main complaint, and originally involved an unusual request to top three of Remingtons alder
24 trees to open-up a small ocean view that was not blocked by Remingtons enormous 50-foot
25 high house structure. Since Remington was rarely on the property during daylight, he refused at
26 least three such requests over probably at least a year, but eventually acquiesced on certain narrow
27 terms, and since no good deed goes unpunished apparently, Randall has caused nothing but
28 problems ever since.
As discussed above and below, Randall is a serious federal contamination defendant but has
557
1 not yet fully implicated himself in the federal RICO case, but is expected to during his first federal
2 deposition, or earlier in his federal written discovery responses.
3 When Randall approached Remington he gave him the impression that he would be there in
4 the house across the street, essentially forever, and certainly inferred that he owned the small house
5 and therefore, topping a few trees would substantially raise his property value, if it had an ocean
6 view. When Randall moved no more than a couple years later, Remington was kind of irritated to
7 learn that he never was the owner at all, but was merely an obnoxious and rather brazen month-to-
8 month renter and good salesman.
9 As explained somewhat above, Remington eventually capitulated to Randalls impassioned
10 requests to simply top three trees, with his own equipment, but then after Randall had unlimited
11 access, he abused his limited permission while Remington was away and cut about 10 alder trees
12 about 3 feet from the ground. Then he stole all the wood, dumped some personal trash underneath
13 the branches in several underground crevices, trampled all the vegetation, which cumulatively
14 eventually destabilized that entire steep bank, causing a major and very serious slide in 2013.
15 Generally, Randall abused his access, took advantage of and spoiled our relationship.
16 Apparently, he was also friends and drinking buddies with the Mathsons and his local
17 Westgate gang and then when Gans needed another perjurer to connive against Remington on their
18 frivolous now defunct and withdrawn aesthetic nuisance cause of action against Remington,
19 apparently they remembered, or discovered through Mathson Remingtons old enemy Randall.
20 Gans has promoted Randall with great fanfare in 2016, but refuses to disclose the exact or
21 even general content of his trial testimony or to even allow his deposition to date. Randall lacks
22 ordinary decent ethics, but would we expect any different from a friend of both Mathson and
23 Gans? Clearly, if Randall is paid enough, like the other 2016 SOL trial witnesses is already clear
24 that he will say and then solemnly swear to anything Gans asks, as a loyal RICO extortion
25 racketeer would be expected to do. Whether Randall has been scripted to say that Remington
26 contaminated his own property, the entire local environment including Mathsons land, or whether
27 Randall is just going to falsely swear that he sold defendants some 6 perforated pipe in 1998 and
28 thats the only type of pipe that he ever sold them, is unknown at this time. Extensive discovery
will eventually be needed on Randall, but meanwhile he is obviously a fairly important member of
558
1 Gans RICO enterprise, but until we learn the exact specifics of his contamination testimony,
2 projected in this federal contamination case, he is not yet a named as a RICO defendant.
3 The only reason that is still the case, is that he has not yet made any appearances or
4 statement of any kind on the public record in any of these cases, nor has he committed any known
5 and provable federal predicate acts, yet; but, give him and Gans a little bit of time and that is
6 expected to be taken care of imminently and before the next draft of this RICO statement, and FAC
7 in this RICO action. In all probability, as soon as he submits his first declaration or response to his
8 first sworn written discovery requests, he will likely lie and commit perjury, if he remains under
9 Gans corrupt influence and follows his carefully crafted false scripts, as presently planned and
10 certainly anticipated. Gans would not have named him as a witness at all, if he was not willing to
11 follow-up Gans script and falsely testify with some acrimony in the seat about Remington and
12 their non-existent relationships, many years ago. But, expect Randall to remember exact, totally
13 insignificant events from 30 years ago, as if they just happened 10-minutes ago.
14 Remington still feels some acrimony towards Randall for his illegal trespassing, violation of
15 his promises, going exponentially beyond the permissions which Remington had given him
16 regarding topping three alder trees, and then stealing the logs which he was not even authorized to
17 cut in the first place. Next, Randall generally trampled and completely defoliated and eventually
18 destabilized Remingtons entire important Northwest bank. Said bank is only 60 feet from
19 Remingtons massive many hundred ton concrete foundation and large 50-foot tall structure with
20 millions of pounds of weight, and in fact an enormous slide did occur there in 2013 which
21 Remington attributes to Randalls activity.
22 In that 2013 slide, about 1000 yd. of totally finished magnificent rose, bushes and tree
23 gardens dropped over 6-feet vertically, causing thousands of dollars of damages, which involved
24 re-stabilizing the entire bank with a variety of measures including: spreading extensive anchored
25 black plastic above about 100 linear feet of key erosion areas; planning, digging-up and planting
26 numerous new trees below the slide, above the slide and many other counter-slide plantings,
27 irrigation and rehabilitation measures, were also done and which continue.
28

559
1 If Remingtons valiant stabilization measures fail and ultimately his entire structure is lost,
2 the damages of another more than $650,000 would be immediately requested from all RICO
3 conspirators and especially from Randall.
4 Similarly to Kishpaugh, Randall is right on the edge here today, and his first perjured state
5 or Federal trial or Discovery statement will advance him to a page one named defendant, in all
6 likelihood.
7 A-9, Joy Mathson is as explained above a charter member of the enterprise, who started
8 much of this enmity in 2006-8 and has fanned the flames ever since as John Mathsons primary
9 cheerleader, who also gives Gans moral authority and some anger as a motivator. Shes basically
10 angry, hostile and very mentally unstable towards Remington and the world.
11 In August 2016, she was obviously primed, well rehearsed and ready to support her lion
12 husband and co-perjurers, and spent two weeks carrying around a bunch of notes to reminder her
13 of what Gans had written for her to remember.
14 Gans conspicuously did not call her as a defense witness barely holding her as a cleanup
15 batter for this primarily older lady jury where she could appear sympathetic and probably abused.
16 Noticing that, Remington did not call her, because she appeared more than ready to back up
17 John Mathsons perjury, as discussed above. She will be one of the first federal depositions we
18 will conduct, to see if she wants to translate that perjury into a few federal predicate acts.
19 Joy Mathson knows most of the unaffiliated witnesses and is clearly just another soldier
20 dutifully awaiting orders from Gans, who has the same defining objectives as all of them, but with
21 a little more personal anger and animosity: Crush Remington as painfully, nastily and completely
22 as possible in all possible ways; avoid all cleanup costs for themselves; keep Remingtons land
23 which they now occupy rent-free for their lifetime at least; make sure everyone else is happy and
24 well-paid and performing the other three major objectives.
25 She actively recruits a new possible character and factual witnesses and to Remington it is at
26 least even money that either she or her daughter is a close friend or relative working in the
27 courthouse and serving as a paid spy and saboteur for Gans against any document or hearing that
28 Remington schedules, files are attempts to file.

560
1 Between 2012-16, no provable predicate acts by Joy mass and are presently known; however,
2 she is deeply involved here, extremely highly motivated and energetic as a co-conspirator begging
3 for a chance to make a difference and hopefully she will be given that opportunity to swear that
4 John Mathson is not done what hes been accused of, and when that occurs she will be a BIG
5 factor in these cases.
6 A-10, Ryan Plotz, is probably the youngest, greenest and lowest paid lawyer at the Mitchell
7 firm and has been an avid Gans apprentice, assistant and fast-learning understudy, chief researcher
8 and motion writer for approximately the last 2 1/2 years. Plotz is believed to know right from
9 wrong and that he has made a Faustian bargain with Gans which has put him on the low road
10 of advocacy which ultimately around a few more bends leads to prison, on the horizon. He is
11 fully knowledgeable and complicit in everything that Gans decides and does and is fully
12 knowledgeable, especially of Gans subordination of perjury in five major trial witnesses which
13 were powerful enough to reverse the truth over the SOL trial statute of limitations issue; and,
14 WHEN or whether Remington had sufficient knowledge of facts in 1998 or even 2006, to put him
15 on notice that he should or must make $50,000 of inquiries in order to locate some unlikely
16 possible deeply-buried contamination oddly emanating from his then-trusted neighbors yard.
17 Nothing more is really needed here because Plotz has been covered adequately above to put
18 him on notice of the charges against him. All this court really needs to know is that he is still Gans
19 right-hand man, confidant and personal assistant that is continuously at Gans side. Plotz walked
20 with Gans to and from trial for more than 110-straight Court days in 2016, usually sat beside him
21 at trial and at pre-trial hearings frequently, and knows and agrees with whatever corrupt schemes
22 and acts that Gans plots and does.
23 Plotz is a very chief figure here. When this enterprise is investigated by the criminal
24 authorities, beginning in the Humboldt County district attorneys office, he would be a prime
25 initial target for interviewing, investigating and deposing. Whether hes a better initial target than
26 Joy Mathson, and the 2-3 others mentioned, is a matter of conjecture.
27 Not initially an obvious RICO enterprise ring-leader, but after four months of investigations,
28 intense thought and analysis of his writings and closeness to everything that Gans thinks, does
writes or orders; Plotz was advanced to being a named-defendant for all of the reasons described
561
1 above. Some of the other dicta herein reverts back to the prior October-November research and
2 drafting period, when his disposition, guilt, intentionality and degree of duress and pressures
3 from Gans were more ambiguous. However, when you study what is written and done and then
4 think about it carefully became obvious that he is among the top five most implicated here in
5 RICO scheme.
6 He will certainly be one of Remingtons initial deposition targets in this case either to get
7 federal admissions from him of the truth of all these allegations, or more likely to get flat denials
8 of everything that Remington has accused defendants of doing here, under oath, which will then
9 immediately lead to numerous new provable salient 2017 federal predicate acts for Remington to
10 try this case upon, and for civil or criminal investigatory authorities to study and refute.
11 As alleged above, Remington has had several lesser extortive experiences one-on-one
12 with Plotz (over the past 2 years) and numerous fraudulent email and fraudulent US mail motion
13 and letter exchanges, but none are yet specifically named, presently believed to be criminal
14 violations, or focused enough on yet to recall their detail, and then potentially to be described here
15 as blatant, obvious, provably clear principal federal violations of criminal codes. There have been
16 a couple of borderline personal interactions but a little bit more is now needed to see which
17 direction Plotz is going to go. He has already violated plenty of federal predicate acts, but
18 probably has not elevated himself into the 10-20 (years) category as opposed to the lower level
19 disbarment-type ethical transgressions. By following Gans orders, supervision and editing of his
20 motion documents, Plotz has already crossed the ethical line scores of times, but so far probably
21 has just towed the criminal line, without yet clearly going obviously out-of-bounds or across
22 it, like his mentor, and obviously deserving of a significant prison term. Suspension and temporary
23 disbarment, absolutely. Plotz should not be practicing law under Gans as he does at present and
24 presently is a menace in this community, however it is not Remingtons opinion that counts here
25 but the courts.
26 After filing a RICO action, at the proper time, filing a CCP 128.7 action against whichever
27 attorneys are deserving, will be very simple, and one might think would have quick results, but
28 that remains to be seen.

562
1 A-11, Jeff Nelson is the CEO of SHN, the direct boss of environmental experts John
2 Aveggio and Mike Foget. The former died of natural causes in 2012, contributed to by the toxicity
3 from these sites, and the latter was mysteriously and very prejudicially removed by Nelson during
4 2013-14 while our federal case was on appeal in the Ninth Circuit.
5 Foget had reported here as Aveggios competent and enthusiastic replacement and initially
6 was very excited to continue Aveggios work and was very anxious to preserve his legacy, to learn
7 litigation support and to work with Remington on these projects.
8 Mr. Foget spent a happy and exhilarating, PAID three hours here in summer 2012, and later,
9 going all over the sites, spouting off new ideas on what we should do and noticing what his friend
10 Aveggio had done previously, and inquiring as to what we were were planning to do next, on our
11 fairly limited budget.
12 However, that excitement and motivation was dampened considerably, as described above,
13 during the middle of his visit, by John Mathsons serious intimidation, coercion, extortive and
14 VERY ANGRY, LOUD MENACING threats to stay away from here, get out of here, dont
15 assist Remington in these cases, and then a few minutes later followed with his startling flash
16 photography in the redwood forest semi-darkness, which for an instant always looked and felt like
17 pistol shots with a silencer, etc. In other words, we knew we were dealing with a potentially crazed
18 angry maniac, and just about the time that we had put him out of our mind his simulated shots rang
19 out renewing the fear, breaking the intellectual planning focus and causing us to prematurely leave
20 those areas of the dump, inside Remingtons fence and on Remingtons land.
21 Remington considers Mathsons acts a possible predicate act in view of the fact that
22 subsequent pressure from Gans, Ferriman and their testing-technician faction, or from Nelson in
23 combination with the latter menacing actions and words from Mathson, directly subsequently
24 caused Nelson to pause and decide to get out of his contract with Remington on the minor
25 pretenses that Nelson thought Remington might accept this justification for his egregious contract
26 breach. As explained above, it was that Nelson contract breach and the possibly complex actions of
27 several enterprise members which caused it which is the obvious predicate act, which has now
28 been fully alleged, but which now needs to be further discovered. Alternatively, Nelsons predicate
act here of improperly removing Remingtons sole remaining credible environmental expert in all
563
1 of Eureka, could have been caused directly by Gans inducements, intimidations, extortion or
2 probably just a bribe of future business. Remington could only offer Nelson and SHN another 10-
3 $20,000 of very easy money as possible future remuneration in these cases, whereas the Mitchell
4 firm could offer millions of dollars over the next 10-20 years.
5 Nelson, like Aveggio and Foget well-knew that SHN was hired for only one thing which was
6 litigation Trial support. Trial support does not mean doing some testing, writing a couple of
7 declarations and taking two depositions in the abstract. Everything that SHNs employees did here
8 was for one purpose only which was to prepare to make impressive and accurate environmental trial
9 testimony in front of a jury, plus doing a bunch of tests, reports and related investigations was
10 merely a further foundation for that projected objective of a trial appearance. Nelson is smart enough
11 to understand that. Why would Remington pay 15-$20,000 plus sacrifice another 20-$30,000 of his
12 own time just to take a few depositions and write a few memorandums and then turn-around to find
13 a new expert to go to trial with which would require repeating all those expenses. Further, there were
14 many other legal logistical and expert disclosure and subsequent admission into these cases which
15 may Nelsons unlawful arbitrary decisions even more unworkable, damaging and it was not just a
16 money thing. Rather, once an expert is admitted into the case by the judge, here it was first
17 Aveggio and then Foget, then, after that, they must stay in the case.
18 Experts cant jump in and out of cases at Nelsons whim, and sponsored to his arbitrary and
19 subjective likes and dislikes in a given week. Its a complex, sophisticated quite permanent
20 process to motion the court, and in this case to essentially beg it to allow a replacement expert into
21 the case, to get said expert actually admitted, and then in this case to change the expert from
22 Aveggio to Foget was an especially even bigger deal with this court, because all attempts to admit
23 experts by Remington were strenuously opposed by defendants and only narrowly granted by the
24 court. Especially and additionally prejudicial was the fact that Judge Reinholtsen barely permitted
25 Foget to replace Aveggio, and then after that when Remington had to attempt to replace Foget with
26 the third environmental expert, Dr. McEdwards, thats when defendants and also said Judge really
27 became obstinate and took Remington many hours to respond to and overcome all Gans and
28 Plotzs frivolous written motion objections.

564
1 Nelson knowingly unilaterally destroyed the contract between SHN and Remington and
2 related trial testimony agreements which greatly damaged Remington as discussed elsewhere.
3 However, inferred and directly threatened damages of more than $20,000 are guaranteed; plus
4 $40,000 or more have been requested to compensate Remington for his lost hundreds of hours of
5 supporting educational, support and accompanying management time; finally, were Remington to
6 lose one or more of these contamination cases, whether with or without malicious prosecution or
7 punitive damages awarded to Gans afterwards, potentially SHN could be liable to Remington for
8 contract breach for another $600,000 or more in a worst-case scenario, which hopefully will not
9 occur. Additionally, since Remington alleges all this is part of a RICO enterprises unlawful and
10 corrupt interference with Remingtons contamination trial experts, potentially treble damages
11 for all provable damages could be awarded here, in a proper case.
12 Nelson has been apprised in writing of those possible damages in 2014, however none of
13 them appear to matter overly-rich corporation, so whatever Gans, Brisso, et al did and said to
14 Nelson must have been powerful because they were so obviously highly lucrative. Whether it was
15 blackmail and threatened exposure of SHN, regards to what Ferriman has falsely claimed were
16 tampered with and incompetent tests by SHN; or, whether it was the promise of huge other
17 contracts going forward; or whether it was cash bribery to eliminate all of Remingtons local
18 experts in the hopes of crushing Remington 100%, and forcing him to drop the cases
19 immediately, or whether it was any of a dozen other illegal unethical or merely elicit corrupt
20 alternatives, we just dont know yet.
21 Depositions of Foget and Nelson, plus Ferriman and Blue Rocks low-level boring field
22 technician, and probably the counties counterpart, also named in this complex relationship, are
23 now indicated. Any and all of those individuals may then become RICO co-conspirators, if that is
24 what the facts infer. In any case, Nelson is the ostensible ringleader of all the transgressions
25 described above in this section, and said above depositions are now needed to either implicate him
26 or clear him of a direct federal predicate act, which act, or acts, are now merely inferred.
27 However, today a direct upper-level link between Nelson and Gans, Brisso, Plotz or any upper
28 level of the RICO enterprise has not yet been proven, but is now being actively sought.

565
1 For 5-6 years, John Aveggio and Mike Foget respectively, of SHN, were 100% of
2 Remingtons environmental case expertise, and while they were involved, Gans automatically and
3 perfunctorily made settlement offers in the hundred thousand dollar ($100,000+) range. Slightly
4 insufficient in those earlier years, but close enough to be eventually negotiated. When Aveggio
5 prematurely and tragically died and then Foget was unceremoniously withdrawn by Nelson, all
6 possibility of settlement of any of these cases was removed, died and Gans settlement offers of
7 about $100,000, reverted immediately to zero and have mostly stayed there. There were a few
8 other extraneous variables which Gans considered in deeming whether to end these cases sooner,
9 or to spent another $500,000 or more on their defense, which are deemed too inconsequential to
10 write about here.
11 In summary, however: No SHN experts meant no local environmental expert in
12 Remingtons case, and hence potentially no case at all! Gans saw that several years ago and has
13 deceitfully planned force that situation and to end Remingtons case that way on technicalities. The
14 8 year case records clearly show to date that Gans has considered SHNs experts to be worth
15 about $90-150,000 to Remingtons case and hence to HIM and to Lawrence.
16 Therefore, bribery extortion or other wise corruptly inducing Nelson into making it easier for
17 him to pull all support from Remington than to continue it (despite Remingtons investments in
18 SHNs several employees in excess of $50,000), was a great investment for the enterprise and one
19 that was clearly made because Nelson did pull-out Foget perfunctory here and without any reason,
20 except for the cliche that he doesnt like litigation support, or Remington or his case either,
21 inferentially.
22 This entire Nelson and SHN issue smells bad and implies corruption, racketeering pressure of
23 some kind, undue influence, bribery or unethical or criminal conduct by the enterprise which
24 clearly has strong ties of some sort with Nelson and SHN. A long, well-though-out deposition of
25 Nelson and/or his detailed public testimony at the next trial is now needed to try and determine the
26 accurate and full truth here, because meanwhile, Remington has been very seriously
27 damaged by Nelsons corruption derived from his Gans all RICO enterprise entanglements.
28 A-12. Four (4) additional Mitchell firm RICO members, were fully designated and
described in detail above, and include Brisso, McBride, Kloeppel, and the Mitchell firm
566
1 limited partnership itself. The pertinent and detailed discussions at #2: G-K, are hereby included
2 at this spot by reference as though all eight or more pages were fully set forth here again.
3 6 (e) State whether you allege that the defendants are individuals or entities
4 separate from the alleged enterprise, or that the defendants are the enterprise itself,
5 or members of the enterprise.
6 Four (4) supposedly mutually exclusive possibilities are stated in the afore-mentioned
7 sentence. The simplest response to that semi-syllogistic anomaly is that for the most part all four
8 (4) possibilities apply to this enterprise at different times of the day, month or during
9 different RICO activities. Also as thoroughly discussed above, it is significant that all of the
10 above-named RICO defendants above, except probably for Gans, Plotz and John Mathson spend
11 the majority of their time doing normal, legal, non-corrupt and non-RICO business activities
12 independent of the RICO enterprise, in the normal course of their non-Gans work activity which
13 in most cases comprises the majority of their time in a given month. In other words nearly all of
14 the associated individuals themselves two huge amount of non-RICO work independently of the
15 enterprise, which would be whenever they doing something in a given day which was not involved
16 with the Remington case or involved with pursuing this Enterprises specifically stated objectives.
17 Also, as explained, much of what the enterprise does, perhaps in the 50% range, would be ethical
18 and normal legal motion and case management conferences and the like which have no particular
19 corrupt content in themselves, in the sense of being illegal per se, although if generally relating
20 indirectly overall to the RICO objectives, said ostensibly legal activities still might be 5-10%
21 corrupt and RICO related.
22 Therefore, the individuals comprising the RICO enterprise or very definitely separate from it
23 most of the time, but during a trial or other intense period of activity all members could melt
24 together into the enterprise for some relatively brief period of time. Therefore, rather obviously
25 during that brief period of time, said above-named defendants and associated RICO members
26 with therefore for a limited period of time become both members of the enterprise as well as
27 form the enterprise itself. At the end of that trial or other intense period of activity, 90-100%
28 of said enterprise members plus the enterprise itself might dissolve, become inactive and do
nothing for even a lengthy period, during which time most or even all of the above RICO
567
1 defendants, enterprise members and RICO Associates, and/or employees thereof might do no
2 RICO activities or business, for days or even for much longer.
3 The explanations and clarifications of how the presently 10-named defendants interact in
4 terms of the above paragraph has been explained pretty thoroughly throughout these documents.
5 Also the at least 25 other-named, presently known and/or inferred enterprise members and
6 associated business-related parties that interact here, as they conduct enterprise business, has also
7 been repeatedly explained above. Obviously, some common sense is necessary in determining
8 where the enterprise starts and stops. For example a file clerk that receives and stamps an
9 outrageously corrupt and false Gans motion was just doing their job, is not an enterprise member
10 anymore than the stenographer that records 10 hours of Gans and defendants perjured trial
11 testimony is automatically likely to be an actual enterprise member, or any sort of RICO associate.
12 Many people have been affected, touched or caught under the wheels of Gans corrupt RICO
13 runaway train, so considerable judicial wisdom and discretion is required here. Everyone Gans
14 speaks to about anything or even about Remington is not necessarily an enterprise member,
15 however many that Gans would speak about Remington to are in Gans extortive racketeering
16 enterprise, and many of them may be initially unsuspected but nevertheless investigated. As
17 explained above, RICO enterprise members can be either active or dormant at a given time and do
18 not have to be engaged in actual continuous criminal activity to still obviously be members of a
19 criminal crime family, or in this case a loose association of Gans employees and private
20 contractors, that just happened to all be dedicated to helping Gans illicitly destroy Remington by
21 whatever combination of means it takes, wherein Gans has presently been utilizing a combination
22 of ostensibly legal litigation backed-up by hundreds of criminal and violent acts of vandalism.
23 Further, both an active or dormant RICO enterprise member can still engage in 90% or more of
24 ordinary legal activity and only perform his RICO predicate acts for several hours per month, or
25 possibly even less. However, whenever a dormant RICO member becomes active that would
26 imply that he was performing federal predicate acts at Gans specific or general direction during
27 the period when he was an actual active RICO enterprise member, active here meaning said
28 member was actively conducting RICO enterprise business in pursuit of its objectives, which

568
1 would by definition involved performing illegal acts, conducting similarly corrupt activity in
2 preparation for future illegal acts, or obviously some permutation or combination of the above.
3 In the likely event that there is still some confusion existing here and because this document
4 is long, not that concise or artfully articulated no doubt, and also because sometimes the more you
5 try to explain something the more abstract and complex it becomes, here is another independent
6 response to 6 (e):
7 (A) No entire corporation is yet believed to have actually formally joined, as such, this
8 racketeering enterprise as it is presently understood, and characterized above. RAO if they are
9 incorporated still, or possibly RAOs insurer could be exceptions to that eventually, however today
10 Rich Olson the individual is assumed to be the presumably defunct shell of RAO Corporation,
11 admittedly based on present insufficient information, belief and frequently personally observing
12 their operation. No RAO insurer is yet known or named except as a probable loosely associated
13 member already, but it must be already intimately involved now in the enterprise, because some
14 individual claims adjuster must have communicated already with Kluck, who has managed to
15 already run-up some several thousand dollars of bills in this matter, without accomplishing even
16 one single known objective. All that will change in the next several months, and as new
17 information becomes known it will be augmented and added to the fact here.
18 Linda Lawrence works for a huge corporation but is presently believed to be acting
19 individually as a sort of rogue, overly-emotionally involved and non-objective RICO participant,
20 hence her employer is not yet sued, but could be in the future if they are not fully statutorily
21 protected, and not legally protected as presently inferred. Part of future proposed discovery will
22 involve consulting with various experienced attorneys in that exact area. Gans is admittedly a very
23 good, con-artist and a criminal which Lawrence may not be aware of yet, BUT, as fully explained,
24 she certainly knows now and should have known before. It is inconceivable and highly
25 irresponsible to pay out $300,000 or more over 10 years, without having any clear idea what the
26 money went for, insurance company or not.
27 Nevertheless, after 10 years of Gans false promises and increasingly irrational activities and
28 objectives in these cases, which Lawrence must be partially aware of, at some point, her

569
1 imprudence should be apparent to Allied, and she should be dealt with accordingly, and
2 presumably will be eventually.
3 (B) Otherwise, all of the named defendants and 20-something (today) other non-
4 defendant enterprise associates are considered to be merely a loose association of mostly
5 misguided individuals desperately trying to make an extra few bucks in this difficult
6 Northcoast economy, who are mostly, but not all44, in small businesses, partnerships,
7 governmental bureaucracies or possibly small corporations. Similarly, any other named or
8 specified organizations involved with Gans RICO enterprise not included above, would be
9 considered to be entities separate from the enterprise. For example, the Mitchell firm itself is a
10 substantially corrupted law firm deeply involved in criminally managing and controlling all
11 aspects of this alleged RICO enterprise. However, the Mitchell firm itself is not solely a RICO
12 entity and certainly is not THE RICO enterprise. It does plenty of other, independent work which
13 does not involve defeating Remington, and some of it may even be altruistic, honest or even
14 overall beneficial in nature to this community. The Mitchell firm has at least three known lawyers
15 who have never been seen in these cases at all or apparently involved here, and presumably they
16 are handling their own cases which could be ethically, unethically or criminally handled, but in any
17 event anything that they do are by definition outside of this RICO enterprise, and are hence, also
18 by definition, probably entirely irrelevant here. Although there could be exceptions or gray areas,
19 presumably any Mitchell attorneys who are not directly assisting, complicit with or knowledgeable
20 about specific criminal acts committed here by Gans RICO leadership in conspiratorial collusion
21 with the named attorneys here, are probably fully outside of this RICO enterprise. If the Mitchell
22 firm has an independent paralegal who is not McBride, then that person may-well be
23 knowledgeable about Gans corrupt activities and perhaps is a borderline RICO enterprise member,
24 according to future discovery. Another Mitchell firm borderline RICO member was originally in
25 fall 2016 thought to be Kloppell who frequently appears at perfunctory hearings when no one else
26 wants to or everyone else is on vacation. He had never been seen, or at least recalled, to express
27 44
Obviously there are major exceptions to virtually every generalization made here and as was plainly
drafted above, there are many odd, old, retired and otherwise unemployable individuals deeply implicated
28 as witnesses in the environmental portion of this lawsuit, many of which, as explained will soon be
promoted into major and active RICO membership after federal discovery starts. Without listing all of
them again, they do include both Kishpaughs, Joy Mathson, Costa, Hilfiker, Evans, Randall, etc.
570
1 any opinion on any substantive matter, which might infer that he has or ever had any operating
2 details about these cases including about their corrupt content. At least, that is the impression he
3 had originally given Remington in any case; on the other hand, he seems also awfully uncurious
4 about all of this. For example, if Remington was asked to go to war against someone at a hearing
5 to represent Gans in these matters he would have requested and also demanded a complete
6 background about the cases, and whether that briefing would involve the transmission of
7 information of criminal acts being performed is unknown under these circumstances.
8 Additionally, as fully explained above, Kloeppels name was found on too many
9 incriminating documents a couple of months after this original decision to pretty much ignore
10 Kloeppel had been made, so Remington reversed his initial decision. Kloeppel pretends hes
11 gonna calm, dumb and doesnt know anything, but perhaps that was just to disarm Remington,
12 because when it came time to drafting documents Kloeppel not only should have known, But
13 DID know enough to cleverly craft illegitimate and corrupt documents.
14 Therefore, although he might be the least guilty attorney named here in this RICO case, if
15 he is just a little bit criminal and corrupt, thats enough to open up further discovery about him.
16 He therefore should be interviewed and investigated by the district attorney, but he would not be a
17 primary enterprise member or suspect at this moment, sufficient to warrant a deposition,
18 probably; However, from what we do now know about him he must be considered guilty for his
19 knowledge and writings and it is now up to him to prove his innocence during an investigation or
20 when discovery begins.
21 Furthermore, this RICO enterprise has plenty of leadership brainpower as it is presentlyVery
22 well known and understood. Gans, Brisso, Plotz and McBride (plus likely other paralegals or
23 assistants at the Mitchell firm presently unknown) are sufficient to manage and control this
24 relatively small and insignificant RICO enterprise and criminal, non-Mafia family, in effect.
25 This is primarily Gans baby, who is absolutely dedicated to it and he needs little or no help
26 running it or determining what direction to go next, although Brisso and Plotz are also known to be
27 influential and either could stop this criminal operation at any time, however it is a fact that their
28 own financial self-interests in combination with Gans optimistic projections of immediate
victory maintained the corrupt status quo.
571
1 Brisso and Plotz are Gans closes top level professional associates, confidants, frequent and
2 constant helpers, collaborators and advisers, but McBride and Lawrence are also right-up there.
3 The entire Mitchell firm is not needed and not implicated collectively yet, as they still have the
4 facade to maintain of a legitimate, highly-ethical law firm, for now. They were known to be
5 ethical at one time, but that was more than 30 years ago.
6 As this case is investigated by Remington and others, the Mitchell firm and their members,
7 especially Gans and Brissos past or present unethical and/or other criminal activities will
8 inevitably be uncovered. Nothing additional however is necessary to prove any of these RICO
9 allegations against these named defendants, however increased scrutiny and wider investigations
10 during discovery, going-forward are expected to reveal prior ethical transgressions against other
11 victims, however what is absolutely certain now is that: In order for Gans and Plotz to be
12 consistent with their corruption and perjury occurring especially in 2016 in the state proceedings,
13 additional federal predicate acts, especially in violation of 1951, 201, 1341, 1343, 1503 1512-13,
14 1956, and 1983, ARE going to have to be committed because Gans has now guaranteed that the
15 RICO enterprise must now begin and maintain a massive cover-up of their crimes.
16 Therefore, all that Remington and this court really needs to do from here is to continue these
17 proceedings and extensive discoveries, under penalty of federal perjury, and pay attention to,
18 collate and highlight the new Gans-ordered predicate acts, which are now guaranteed to occur in
19 2017 and to be strictly federal, and beyond any equivocation or defense. As was written above, the
20 only real general philosophical question in 2017 would appear to be who else is going to sink,
21 along with Gans in his lifeboat, and will they drown or be rescued by the financial drivers of this
22 enterprise. The RICO members will now have to decide if they want to risk continuing to battle
23 with nature and Remington, for a few more years, analogous to the last hours of the Titanic, and
24 then eventually allow, assist and encourage Gans to inevitably take their whole ship down with
25 them, while they have decided to have faith in him and to believe him that he can fix the gaping
26 damages present in his case.
27 (C) Who is the enterprise? Therefore, at the risk of additional abstraction, the defendants per
28 se are NOT the enterprise, or are not identical to the enterprise because they do plenty of other
independent work which has nothing to do with the enterprises objectives. On the other hand, on
572
1 days, hours or at the times when the enterprise exists, is on the hunt, engaged in federal crimes,
2 and is functioning properly, then the enterprise is no more or less than those defendants, perhaps
3 somewhat like commandos operating behind enemy lines in a war, and what actual illicit activity
4 theyre actually doing to pursue the enterprises unlawful objectives.
5 The named defendants are its most prominent and powerful members who lead it towards its
6 objectives, but are never the entire enterprise which involves to a lesser extent the other 20-30
7 subordinate but important members of the RICO conspiracy against Remington. All members and
8 Associates make-up the enterprise, however like a sports team, some on the team are stars,
9 others are players, others are never used substitutes and then there are managers and administrative
10 personnel which at some point are not really guilty of anything, even if the team for example
11 decided to commit an arson after a victory. In other words, this question can get complex,
12 subjective and quite nebulous.
13 Today, Remington knows quite a lot about and has considerable evidence on the named
14 RICO leaders even before specific discovery takes place here. Remington knows about and has
15 thoroughly described numerous federal and/or state fraudulent and RICO predicate acts, but now
16 needs discovery, more evidence and one or more of Gans witnesses to come forward and tell the
17 truth. At some point, the thousand dollars ($1000), more or less from Gans, his smile, charisma
18 and encouragement about the justification of his cause, may be insufficient to risk major fines or
19 prison time for some of these RICO members and associates.
20 Because Gans and his Mitchell leadership have zealously covered-up all of their illegal and
21 unethical activity here since 1998, which is the basis of this enterprise, once it is fully exposed here
22 to all of its members, to law enforcement and to the Humboldt County judicial system, more
23 informant members may come forward and in any case plenty of new information will be revealed
24 imminently, when sworn, well-targeted written and oral discovery begins.
25 Additionally, more reckless and illegal acts of violence, vandalism, destruction of Burl Tree
26 property, coverups, and possible attacks on Remington himself are anticipated and expected from
27 several of the named soldiers above. Since that is a given, our numerous lighting systems
28 cameras and other electronic surveillance methods will be ever vigilant, 24-7, and, in fact, we
are even counting-on gathering significant additional information in order to provide the straw
573
1 that will break Gans back, so to speak and directly cause and conclusively lead to the complete
2 sinking, and ending, of this enterprise ship for the good of all involved or living near here, and
3 sooner instead of later.
4 (D) SUMMARY: When this was initially drafted in October-November 2016, 31 individuals
5 had been named here, plus a few others unnamed so far, as bona fide enterprise members but
6 only 11 were initially designated as RICO defendants due to the better evidence of actual crimes,
7 which we had against them.
8 By 2017, that 11 was reduced to 10, but then after several months of MUCH more
9 continuous study, that 10 was raised to 12, and many names were changed during that period, from
10 what initially seemed correct during fall 2016 based on additional kinds of analysis. However, the
11 present group of 12 are expected to increase by 2-10 during 2017 Discovery, after certain needed
12 additional evidence is procured. That means that some of the other 20-25 who are mentioned
13 already and suspected of significant RICO wrongdoing herein, will eventually be named and
14 hopefully (or conceivably) some of the present 12 named defendants will be de-designated,
15 probably only after they decide to turn states evidence, or to tell the truth about this
16 enterprise, or even just tell the truth about something or anything, and especially about Gans
17 specific illegal activities, or anything related thereto.
18 As above, most, but not all of the individuals involved as RICO enterprise members are in
19 various organized businesses, discrete entities or related groups, but are generally named as
20 individuals and not as entire businesses in most cases. Gans misleads, corrupts and deceives
21 individuals and not business names.
22 Much of the worst corruption to date in these cases have involved Mathsons union, drinking
23 and drug-using buddies, social associations or other personal friends, etc. Gans mostly uses
24 individuals for his nefarious purposes which individuals may or may not be working for someone
25 at the time, and if so that work relationship is not specifically relevant to their criminal RICO
26 membership in most cases. Examples of that would include, without limitation: Randall, Nelson,
27 Dalka, Hubbard, the Superior Court file room saboteurs, Hillyard, Hilfiker and several of Gans
28 numerous experts, including some that have not even become involved in these cases yet.

574
1 Therefore, again perhaps repetitively, the named defendants are only part of the enterprise
2 and only part of the leadership also at this point, as the entire enterprise itself consists of at least all
3 31-35 named individuals and organizations herein, plus inferentially another 5-10 more support
4 or logistical personnel, that are as yet unnamed and substantially unknown, but rather obviously
5 must also be present in order to make some of these enterprise associations function properly, or to
6 support various individuals that are named herein, examples of which would include: secretarial
7 and clerical services, researchers, bookkeepers or electronic sales people or repairmen.
8 A good, further example that relates to the above paragraphs would be KLUCK, who appears
9 to be the attorney for RAO, Olson and Skillings, although that has never been fully, satisfactorily
10 or officially designated, confirmed or ratified, especially as regards to this RICO and federal
11 case.
12 Whether Kluck is a present enterprise leader or just a soldier at this point is not fully known.
13 Today, he has a very, very passive role, but he obviously yearns to rise higher into a position of
14 command and respect, and to be a RICO enterprise leader, and inferentially he is probably in the
15 habit of giving more orders than he receives. Today he reports to and depends 100% on Gans for
16 all communications and documents within these cases. Why that is, is unclear, and whether that
17 will continue throughout 2017 is also unknown. Obviously, Kluck trusts Gans more than he trusts
18 Remington, and at the moment he prefers to receive all of his documents in the case directly from
19 the Mitchell firm, and has never requested anything from Remington, although Remington usually
20 serves them with any document which may affect them directly. To Remington, that is a
21 significant fact, which does not need to be expounded on here at this time.
22 The last status conference in DR140426 was scheduled for February 17, 2017, and all
23 participants requested another 60-day stay. Remington filed a detailed brief, but did not attend and
24 depends upon the court to update him about the next management conference, however as
25 complained of above, nothing has happened and Remington appears to be stricken from the courts
26 service list once again. During April he will need to find out what happened. Whether that case
27 was stayed or whether it becomes active and discovery begins during April is not presently known.
28 In any case, Kluck is imminently expected to begin an active membership in Gans RICO
enterprise and likely is destined to take over a co-leadership role, because his clients Olson and
575
1 Skillings play very prominent roles herein. After all, it was their corruption45 that began all of this,
2 however, Gans went way-beyond Olsons original criminal hauling and dumping scheme to
3 develop his own convoluted, involved, SUPER-EXPENSIVE and entirely unnecessary RICO
4 cover-up described herein. Kluck and the RAO defendants would appear to have no choice now
5 but to support, back, enhance and continue Gans corrupt cover-up and perjurious litigation
6 practices, but one can never tell with Kluck, because he is pretty slick and slippery in his own
7 right. He also appears to be a bit too old and smart to risk landing in a prison cell somewhere, so
8 he will be watched carefully.
9 6 (f) If you allege any defendants to be the enterprise itself, or members of the
10 enterprise, explain whether such defendants are perpetrators, passive instruments, or
11 victims of the alleged racketeering activity.
12 As appears to have been adequately explained above, none of the named defendants would
13 be the enterprise itself, but when you add-in all 30-40 enterprise members and associates named
14 herein you may have most or all of the guilty individuals, but until they actually act and perform
15 provable predicate acts either previously or in the present, you dont really have a complete
16 prosecutable RICO enterprise. Illegal actions by the Enterprises members are necessary to form an
17 illegal enterprise where the members are worthy of going to prison. Analogously, a bunch of Mafia
18 soldiers sitting around in a room would be difficult to prosecute and imprison without any
19 provable illegal acts, so its the proof, witnesses and related evidence thereof, which is crucial here.
20 (1) Victims? None of the presently named RICO defendants, other associates, less important
21 members or their supporting personnel, are victims of this Enterprises illegal acts or plans.
22 Remington is the primary victim of this RICO enterprise, as is his business, family and a large
23 number of adjacent neighboring residences both upwind and downstream from defendants
24 contaminations.
25
26 45
The reader hopefully recalls that the Mathsons, RAO, Olson and Skillings, et als unlawful but very
27 profitable criminal scheme, was based on his creative establishment of a Class I hazardous waste dump in a
coastal-zoned, unsuspecting residential area redwood forest with a 20-hour shorter trucking distance and no
28 dumping fees, and all of these subsequent lawsuits are based on that original crime, subsequent cover-
up and Mathsons, Gans and all environmental defendants refusal to remove their contaminants which
they admittedly dumped-on and specifically buried on Remingtons property.
576
1 (2) A perpetrator is defined here as someone who actually commits a specific illegal act
2 as opposed to just ordering that it be done. Also, a perpetrator will have done something
3 wrong, or committed any illegal or evil act, which is often a crime, such as violating moral or
4 civil law, as opposed to merely planning and ordering same. On the other hand, the mere
5 planning and ordering is believed by plaintiff to deserve either worse or at least equal
6 punishment to that received by the individual order to perform the crime. Analogously, Hitler
7 would be considered more culpable, guilty and worthy of punishment than his soldier that killed
8 someone under his direct order, or say loaded a thousand Jews onto a boxcar for the crematoriums.
9 As used herein, perpetrator refers mostly to those that actually physically carry-out illegal
10 acts of violence, vandalism, burglary or extortion. The leadership would not necessarily be
11 perpetrators under that definition, however they could be under expansions or qualifications of
12 that term. For example a Mafia godfather that just sits in a chair issuing orders, would generally
13 still be considered to be the most responsible and guilty person in the enterprise, even if he only
14 issues orders and never personally kills or injures anyone, wherein he might not be considered to
15 be a perpetrator, under this definition. For purposes of this document, Remington will apply that
16 strict definition of perpetrator as meeting the one that actually pulls the trigger and commits an
17 illegal act as opposed to planning it, ordering it and then standing there watching while it is
18 committed. Similarly, as explained sufficiently, the criminal leader would usually be just as guilty
19 as the perpetrator and in many situations would be up to 1 million times more culpable and worthy
20 of punishment.
21 Therefore, under the above definitions an explanation, Perpetrators that are relevant in
22 this RICO case do not automatically include the most guilty ones here, which are the RICO
23 leaderships nucleus of master planners, managers and controllers of policy and who plan in order
24 what specific individual corrupt, unethical or illegal directives are given to the members. Rather,
25 the word perpetrators as narrowly defined herein defines the actual evildoers themselves who if
26 observed committing illegal acts would be immediately guilty of a crime. That is one of the
27 primary beauties of RICO law: Not only is the perpetrator of the actual criminal act guilty, but all
28 those that planned the heinous crimes and issued the criminal orders are at least as guilty as the
perpetrators and morally would appear to be even more guilty, if anything. In other words,
577
1 Remington would argue that Hitler himself was more guilty of war crimes than a Nazi foot-soldier,
2 his commanding officers and generals.
3 The alleged RICO enterprise perpetrators here, as of January 2017, who have actually
4 committed known federal predicate acts and not just planned, ordered them and/or watch them
5 being executed, would include: Gans; John Mathson; Olson and Skillings (of RAO); Lawrence,
6 Plotz, Brisso, Jeff Nelson (on a limited basis); Morgan Randall; Jon Kishpaugh, Costa and Joy
7 Mathson; Ferriman, Hillyard and Gwinn; Martel and Esko; Probably at least Liz Smith and/or
8 Candy B, but subject to further investigation and discovery; there are also other possibly inferred
9 or sensitive likely perpetrators, which have been named herein and rather extensively described
10 above, subject to and pending, the extensive discovery which is now planned, who are presently
11 omitted from the above list.
12 For example, Kluck is not yet fully categorizable because he has done almost nothing here
13 yet, and the same would appear to apply at this time to RAOs insurer whoever that is; similarly,
14 Judge Reinholtsen is presently in an ambiguous and somewhat untouchable position as a present
15 state trial judgeActively adjudicating Remingtons 2008 case DR 080678, who presently appears to
16 be determined to remain such, but one who is going to be subject to future federal and/or state
17 discovery or investigation, at some point.
18 Those named in the above paragraph, are all implicated and/or guilty to totally different
19 and greatly varying degrees ranging from minor perpetrators to major felonious perpetrators,
20 and in several of the obvious cases above, many of those named are both planners and
21 perpetrators, and might also be accessories to perpetrators without taking on that designation
22 themselves. Complicating generalities further and making them basically inexact in many and
23 probably most cases would be the fact that many if not most of the crimes here were not simple
24 extortion or destruction of property. There have been a wide variety of actual crimes committed
25 here against Remington ranging from white-collar crimes such as wire, mail and or the financing
26 of known frauds and extensive and determined perjury, to actually physical vandalism, arson,
27 burglary, theft and threatened violence, etc.
28 The law assigns financial and prison penalties to all of these types of crimes and naturally
courts are familiar with evaluating their severity in terms of the codified law, all of which is
578
1 beyond Remingtons interest or experience, so he will not pass any judgment at this time here
2 about who on the above list may deserve the worst penalties and punishment.
3 However, in that regard, Remington did evaluate some of the above list on a scale from 1 to
4 10 in about November 2016, with the indirect purpose of assigning blame and guilt as Remington
5 might do if he was the judge and adjudicating what jail sentences would be appropriate herein.
6 Although probably irrelevant and certainly not emphasized here, the present evidence might
7 indicate as follows for these limited examples: Gans, 10/10; Lawrence, 5/10; Skillings and Olson
8 so far to date, 7/10; John Mathson, 9/10 (although merely a passive instrument and entirely
9 subordinate to Gans planning and direction); Plotz and Nelson, perhaps 3.5/10, based on the
10 limited knowledge available and many other related factors.
11 (3) The Godfather and his inner circle. As philosophically alluded to above, arguably the
12 worst offenders here and most guilty defendants in this RICO enterprise are not even listed as a
13 category by the judge that designed this RICO statement. Remington takes issue with that and
14 asserts that there should be at least a third and top category of RICO enterprise leaders, CEOs
15 and/or top generals, which would include the overall leader or godfather of the enterprise. That
16 category is listed right here, and the top leadership person alleged here is Gans and his other top
17 leadership and CEO team, which includes the other named members within the Mitchell firm.
18 This third group of top enterprise leadership are not necessarily perpetrators except to some
19 minor extent, or as in the case of Gans, major extent. Whether Plotz and Brisso are major
20 perpetrators, because they followed and efficiently executed orders from their legal partner Gans is
21 essentially for this court to decide and Remington will presently defer any judgment thereon.
22 (4) Theoretically and actually, which RICO members here were perpetrators, aiders and
23 abettors and accomplices, and what are the relative culpabilities of each in this case, and why?
There are numerous other factors relevant to culpability between or among RICO leadership and
24
lower-level perpetrators of crimes, and of course there may be some additional overlap where the
25
leadership actually perpetrates the crimes directly.
26
Other factors are intent, foreseeability, actual participation in a crime or aiding and abetting
27
such crimes or acting as a co-perpetrator in a crime
28

579
Gans always had effective control over Mathson, had been told about Mathsons crimes for
1
years was put on notice of all details of said crimes and he always had the power to instantly
2
prevent Mathson from committing additional crimes.
3
What were the gravity of Gans crimes? The degree of suffering and vulnerability of the
4
victims factors into that.
5 Planning, instigating ordering, committing, and aiding and abetting may be performed
6 through positive acts or through culpable omission. In situations where a person in authority has
7 a duty to suppress unlawful behavior of his subordinates of which he has notice of but does
8 nothing to suppress that behavior, the conclusion is allowed that the person by positive acts ort
9 culpable omissions directly participated in the commission of the crimes through one of the
10 various modes of participation.

Gans extensively aided and abetted Mathson by rendering practical assistance,
11
encouragement, moral support and the promise of legal assistance all of which is a substantial
12
effect on the perpetrators crimes. Mathsons destruction of Burl Tree property was serious and
13
affected Remington's livelihood and ability to make a living; additionally defendants harassed,
14
humiliated, degraded and psychologically abused Remington for many years.
15 The culpability for the Planning, instigating, and ordering of the crimes is generally different
16 from the actual commission of that crime and involves different responsibility, arguably more
17 responsibility.
18 Both positive acts and omissions may constitute instigating a crime, as well as express and
19 implied conduct needs to be considered; when Gans ordered Mathson to commit various crimes
20 no formal superior-subordinate relationship need be proven nor does the order need to be in
writing and the relationship and process can be proven by circumstantial evidence, which we will
21
do here.
22
Generally, Gans RICO enterprise involved the plan or purpose and arrangements or
23
agreements between two or more persons to commit various crimes, and thereafter they did
24
commit those crimes in unison, which infers that plan. No other reasonable inferences are
25 reasonably possible from the evidence, which we have expressed here.
26 If Gans uses the same group to attack another person with a different objective, then a new
27 joint criminal RICO enterprise would be formed. Whether that has been done yet or in the past,
28 remains to be discovered.

580
A participant in a RICO enterprise must perform acts directed at furthering the common plan
1
or purpose, however to be a participant in a joint criminal enterprise, one need not be physically
2
present during the crime; all participants are equally guilty regardless of the exact part they
3
played, however "participation" is not automatically satisfied by mere membership in the
4
enterprise, because "involvement" must form a link in the chain of causation.
5 To be guilty of a RICO violation the perpetrators state of mind must be proven and it must be
6 the only reasonable inference available. It is not necessary to show complete agreement with
7 respect to every crime committed; however, there must be a common plan to commit the crime
8 charged.
9 Gans had effective command responsibility and authority over all of the enterprise members
10 which he paid. That means that Gans had effective power to control the perpetrators, and he also
had actual knowledge of the crimes being committed by Mathson and his Westgate gang.
11
Gans sometimes was an active direct and personal participant in some of these acts and was
12
a co- perpetrator at that time. Premeditation is present here and Mathson and the RICO defendants
13
were all informed, voluntary, willing, enthusiastic or zealous participants in the crimes.
14
Each of the named RICO defendants committed various specific crimes which is defined as:
15 the accused participation physically or otherwise directly in the material elements of a crime
16 provided for in the statutes through positive acts or omissions, whether individually or jointly
17 with others.
18 Gans planned and perpetrated Mathsons destructive acts of vandalism and property
19 damage against Remington with the clear intent to spread terror to Remington and his family.
20 Gans was also specifically and repeatedly put on notice of these crimes committed by his
subordinates over whom he had total control and he consistently for many years failed to prevent
21
the commission of these crimes or to punish Mathson or his co-perpetrators of which he had
22
knowledge. Conclusions of that type may rest entirely on inferences since Remington has no
23
witness testifying to hearing Gans issue such orders nor do any written orders exist.
24
Mens Rea is a relevant concept here and is a legal phrase used to describe the mental state a
25 person must be in while committing a crime in order for it to be intentional. It refers to a general
26 intent to break the law or the premeditated plan to commit a particular offense. Gans Mens Rea is
27 relevant here and when he purposefully ordered Mathson to commit acts against Remington that
28 would make Gans culpable for and just as responsible, guilty and willful as the actual/actor of the
criminal act.
581
Generally, Remington alleges that Gans planned the extortive racketeering against
1
Remington meaning that he designed the commission of a series of vandalistic crimes, at both the
2
preparatory and execution phases, and the actual criminal vandalisms actually committed within
3
that framework by others such as Mathson and Kishpaugh.
4
To assess the seriousness of the RICO act crimes against Remington, consideration must be
5 given to all of the factual circumstances. These circumstances may include the nature of the act or
6 omission, the context in which it occurred, the personal circumstances of the victim including age,
7 sex and health as well as the physical, mental and moral effects of the act upon the victim or his
8 family.
9 For crimes of persecution, harassment, vandalism or any of the crimes alleged against
10 Remington here, Remington must show that the RICO named defendant shared the common
harmful objectives and intent of the joint criminal enterprise. If the accused does not share the
11
enterprises intent, then he may still be liable as an aider and abettor if he knowingly makes a
12
substantial contribution to the crime.
13
A direct perpetrator/actor is another way to characterize the one, for example John Manson,
14
that conducts the crime, and there may be indirect perpetrators also involved, for example Costa
15 and Kishpaugh.
16 A person who orders, plans or instigates an act or omission with the awareness of the
17 substantial likelihood that a crime will be committed in the execution of that order, plan or
18 instigation has the requisite mens rea for establishing liability for said ordering, planning or
19 instigating, which means such awareness is regarded as accepting that crime, and in that regard
20 they may be liable for that crime.

Over the last four years the RICO enterprise has willfully caused Remington great
21
suffering by means of exposing him to numerous deadly and life-threatening toxins which has
22
made him nearly fatally ill three times since 2013 including an 8-day hospitalization, where no
23
progress was made there and it took another two months to rehabilitate at home. The enterprise
24
inflicted that punishment out of revenge, sadism or the desire to cause mental, emotional and
25 moral suffering. The pain and debilitation was serious because Remington was incapacitated for
26 work for more than a year. Said serious harm need not cause permanent or irremediable harm, but
27 must involve harm that goes beyond temporary unhappiness, embarrassment or humiliation; and,
28 here Remington's mobile stability and hearing has been drastically impaired by more than 50%. In
other words, defendants harm to Remington has resulted in grave long-term disadvantage to and
582
destruction of his ability to lead a normal and constructive life, which possibility is now
1
impossible.
2
The aider and abettor must be aware of the essential elements of the crime committed by the
3
principal offender and mastermind, Gans, including his state of mind. However the aider and
4
abettor need not share the intent of the principle offender, but merely must be aware that what he
5 is doing is wrong and is some sort of a crime.
6 Additionally not only the persons who physically perform the criminal acts are liable but
7 those that assist the perpetrator physically to help them carry out that act can also be culpable,
8 such as with a criminal conspiracy or joint criminal enterprise. In other words the actual
9 commanders of the crimes are not the only guilty ones because it is often the participation and
10 contribution of the other members of the group which is vital to facilitating the commission of
any given offense. Hence the moral gravity and culpability of such assistance and ancillary
11
participation is often no different from that of those that actually carry out the criminal acts in
12
question.
13
In our RICO enterprise case, there are perpetrators and accomplices which also blend-in
14
with co-perpetrators, and they all may be the same thing. In other words, often there's no such
15 thing as aiding and abetting a crime but that person should be regarded as having actually
16 committed that crime if participating in a joint criminal enterprise as a co-perpetrator. That is
17 because when a participant shares the purpose of the joint criminal enterprise as opposed to
18 merely knowing about it, he cannot be regarded as a mere aider or abettor to a crime
19 contemplated.
20 For one to be considered a co-perpetrator it suffices that there was an explicit agreement or
silent consent to reach a common goal by coordinated co-cooperation and joint control over the
21
criminal conduct. For this kind of co-conspiracy there is a known common purpose or plan which
22
is either implicit or explicit and therefore criminal responsibility may be imputed to all
23
participants within the common enterprise as a predictable consequence of the execution of the
24
common criminal design, and if the accused was either reckless or indifferent to that risk
25 Generally, defining individual criminal responsibility in the criminal enterprise the elements
26 which must be established are: 1) a plurality of persons; 2) existence of a common plan, design or
27 purpose which amounts to or involves the commission of a crime provided for in the statute; and
28 3) the participation of the accused in the common plan involving the perpetration of one of the
crimes provided for in the statute; 4) the shared intent between all the participants to further the
583
common plan or design involving the commission of a crime. The arrangement, which leads to
1
the commission of the crime by the enterprise, need not be an express agreement but may be
2
inferred from the fact that a plurality of people acted in unison.
3
The most important thing is to prove that the RICO participants were involved in the
4
system and had knowledge that it was intended to damage or defeat Remington in these
5 litigations, whereas actual knowledge of the details of the plan and proving a formal agreement
6 between all the participants to establish that objective is not important.
7 In order to be culpable as a RICO defendant there is no specific legal requirement that the
8 accused has made a substantial contribution to the joint criminal enterprise, in order to be
9 considered to be a co-perpetrator. It is sufficient for the accused to have committed an act or an
10 omission, which contributes to the common criminal purpose. Kvocka et al (appeals chamber)
Nor is a participant in a joint criminal enterprise required to be physically present when and
11
where the crime is being committed, but his guilt would be dependent upon the evidence.
12
What is important here is shared intent, and plaintiff must prove that the persons charged
13
including the principal offender or offenders had a common state of mind which was required for
14
that crime.
15 Unanimous agreement is not necessary, but some common intent to commit the crime
16 charged is needed. Intent can be inferred from knowledge of the crimes being perpetrated and
17 from continued participation in those crimes, however ultimately it depends in the final analysis
18 on the evidence and the specific circumstances of the case. Such intent may be proved either
19 directly or as a matter of inference from the nature of the accused authority and specific actions
20 within the organizational hierarchy.

We can also attempt to distinguish between motive and intent. The personal motive of the
21
perpetrator of a crime against Remington for example may be to obtain high wages, approval
22
from Gans and prestige as a trial expert, for example. Whereas the existence of a personal motive
23
to get paid does not preclude the perpetrator from also having the specific intent to gravely harm
24
Remington and his business such as in the examples of John Mathson and Kishpaugh cited.
25 Further, it is not necessary that every member of Gans RICO enterprise know about each
26 crime committed in order to be criminally liable. All that is necessary is that they know that some
27 crimes are being committed or some deceits are being practiced for that to all be sufficient
28 knowledge that a criminal enterprise is functioning here. In other words, the intent to participate
in foreseeable crimes against Remington must be shown and also that these RICO defendants
584
willingly took the risk, especially going forward now, that additional crimes might occur and as
1
alleged herein are CERTAIN to occur in the future. That means it is now entirely and totally
2
foreseeable that additional crimes will be perpetrated by one or more members of Gans RICO
3
enterprise, as a natural and foreseeable consequence of the agreed joint criminal enterprise, and
4
therefore all readers of this document have been adequately put on notice thereof, and henceforth
5 will have willfully taken that risk, and effectively decided to continue to participate in Gans
6 enterprise.
7 The distinction between "aiding and abetting" and actual perpetration of a crime is
8 significant. Joy Mathson is a good example to consider in terms of the following criteria, as she
9 has always been the primary aider and abettor, but probably never an actual perpetrator, however
10 see below for analysis of whether she is just as guilty as anyone else here.
A. The aider and abettor is always an assessory to a crime perpetrated by another person the
11
principle who here was primarily John Mathson and members of his Westgate gang;
12
B. In the case of aiding and abetting, no proof is required of the existence of a common
13
concerted plan let alone of the preexistence of such a plan. No plan or agreement is required and
14
the principle conceivably might not even be aware of an accomplices contribution, however in
15 this example Joy Mathson is known to have enthusiastically contributed to the planning;
16 C. The aider and abettor carries out acts specifically directed to assist, encourage or lend
17 moral support to the perpetrator of a certain specific crime which year was the wanton destruction
18 of Remington's gardens, business and residence, and that support had a substantial effect upon the
19 perpetration of the crimes. By contrast, in the case of acting in pursuance of a common purpose or
20 design, as Mathson did under Gans directions, it is sufficient for the participant to perform acts
that in some way are directed to the furthering of the RICO enterprises common plans and
21
purposes.
22
In this example of Joy Mathson, in order to be guilty of aiding and abetting the requisite
23
mental element must be shown that she had knowledge of the acts committed by the perpetrator
24
and was aware of the specific elements of his crimes.
25 Here, Joy Mathson also shared the mens rea of the principle, who here was mostly John
26 Mathson who physically carried-out numerous destructive crimes. However, in the case of Joy
27 Mathson she had a much broader knowledge of the entire Gans RICO enterprise objectives and is
28 known to have done her best to assist with the suborning of perjury with all of her friends along
Westgate Drive; and, therefore ultimately SHE should be found criminally responsible for all
585
of the RICO crimes committed against Remington in furtherance of Gans common
1
purposes, equal to a co-perpetrator.
2
In other words, overall Joy Mathson may be a mere aider and abettor of, or "accomplice"
3
(which is ordinarily considered to involve less culpability that an actual perpetrator) to some of
4
the local crimes against Remington; but, overall, and over an extensive period, She became
5 directly involved in all functions of the enterprise and since she not only had specific advance
6 knowledge of the crimes which the enterprise intended to commit against Remington, but she also
7 shared the intent of the joint criminal enterprise by the time of the 2016 SOL trial, she had
8 become a co-perpetrator, which status will continue into this federal case during discovery,
9 because presumably she will now lie about her total involvement in a federal forum, hence
10 automatically becoming liable for its punishments.

Therefore, although her initial mere aiding and abetting might have been considered to be
11
a lesser degree of criminal responsibility than the persons that actually commit the crimes, here
12
as argued overall she is not just an assessory to the co-perpetrators but since she shares their
13
intent and objectives, there would be no reason to grant her any leniency based upon the present
14
facts. In other words, Joy Mathson should be considered to be a co-perpetrator and in the next
15 complaint, and in the federal trial, she will be named as a primary RICO defendant, unless she
16 immediately agrees to tell the truth.
17 What of Gans command responsibility for the criminal acts of the enterprise? The fact that
18 soldiers such as Mathson committed criminal acts on his behalf does not relieve him of criminal
19 responsibility if he knew, had reason to know, or should have known that Mathson was about to
20 commit such acts or had done so previously, and Gans had failed to take the necessary and
reasonable measures to prevent such acts in the future, or to punish the perpetrators, such as
21
Mathson and Kishpaugh for their previous crimes. That principle of individual criminal
22
responsibility of superiors for failure to prevent or punish crimes committed by their subordinates
23
is an established principle of international as well as domestic law.
24
The elements of this type of guilt against Gans are well-established under international law, and
25 are:
26 1. The existence of a superior-subordinate relationship;
27 2. The superior knew or had reason to know that the criminal act was about to be or had been
28 committed; and

586
3. The superior failed to take the necessary and reasonable measures to prevent the criminal act or
1
to punish the perpetrator thereof;
2
4. In this situation the superior is assumed to have command, EFFECTIVE CONTROL, and the
3
power to control the acts of the perpetrator, forming the basis of his duty to act, or failure to do so.
4
In this RICO enterprise, Gans has and HAD absolute and full effective control over all of the
5 named RICO enterprise members, especially the soldiers and lower-level perpetrators such as
6 Mathson and his Westgate gang.
7 He also had mere influence on them as well, however overall, as will be proven by evidence,
8 any orders that Gans issued were absolute and always obeyed. In order to ascertain what degree of
9 absolute control Gans had, there is no need for any formal position of authority, whereas his
10 actual authority would have to be assessed based on the reality of the actual authority that Gans
had over his men. Can they prove that they refused to obey any criminal orders, which Gans
11
issued? We presume not.
12
The most obvious proof of the superior-subordinate relationship between Gans and his men
13
would be shown by the formal hierarchical relationship between the superior and the subordinate,
14
and whether that relationship is direct or indirect. The permanence or length of time of the
15 command relationship is not important, but merely whether effective control of particular
16 individuals was exercised by Gans based on the control of actual monetary payments being made
17 and the promise of many more to come if the various perpetrators or RICO members continued to
18 properly follow orders essentially act and testify against Remington per RICO objectives.
19 Similarly, under requisite international legal principles, two or more superiors may be held
20 responsible for the same crime perpetrated by the same individual if it is established that the
principal offender was under the command of both superiors at the relevant time, which here
21
would include the entire Mitchell law firm leadership, any of which were capable of exercising
22
individual control over any specific RICO enterprise member. As to whether a specific superior or
23
member of the Mitchell law firm had the requisite level of control, that is a matter to be
24
determined on the basis of the evidence presented in this case at trial.
25 Gans can be proven to have had actual knowledge of Mathsons criminal acts because he is
26 geographically close to the sites and frequently visits those sites to supervise Mathsons crimes
27 and other works. Circumstantial evidence of Gans actual knowledge that his subordinates were
28 committing or were about to commit a crime includes: the number, type and scope of the illegal
acts, the time during which the illegal acts occurred, the number and types in scope of illegal acts,
587
the time during which the illegal acts occurred, the number and types of RICO members and the
1
logistics involved, geographical location of Mathsons destructive acts, and whether the
2
occurrence of the acts is widespread and similar to other alleged virtually identical acts.
3
Did Gans have "reason to know" that his RICO soldiers were committing or about to
4
commit various crimes against Remington? The answer to that is obviously yes, because
5 Remington went out of his way to complain about Mathson's destruction of his property and
6 gardens in virtually every declaration and amended complaint filed in these cases since at least
7 2012. That had to put Gans on notice of all of the destructive acts by Mathson and his gang
8 including the severity and frequency thereof. Gans not only had general information but very
9 explicit and specific information of most of these criminal acts by Mathson.
10 In other words, Gans has always had the power, duty, ability and the knowledge to prevent
Mathsons criminal acts against Remington, but he failed the take necessary and reasonable
11
measures to prevent the commission of numerous crimes or to punish Mathson for the acts which
12
only he could have committed.
13
Overall, the above considerations would make Gans the co-perpetrator in all of the
14
Mathson crimes to which Gans acquiesced and had continuous actual direct and future advance
15 knowledge thereof, or should have had reason to know. Additionally, Gans had the obligation
16 under all types of criminal, civil and humanitarian law to attempt to prevent crimes being inflicted
17 upon Remington and therefore had a responsibility to control the acts of his RICO members,
18 however here he failed to act, investigate or make any effort to stop Mathsons crimes, and is
19 therefore culpable, which facts need to be taken into consideration at the punishment stage.
20 Additionally, at the punishment stage there are MANY and numerous other factors to
consider which go beyond the scope here.
21
22
23 (5) The final category of 6 (f) is entitled passive instruments. That term is imprecise and
24 certainly not clear here. RICO enterprise members who are not perpetrators or leadership
25 members of the Godfathers inner circle, might be construed as passive instruments, however,
26 as alluded to above, it is hard to make a class of such members. Some of the members may not be
27 facilitators ordinarily, but might initiate, support or facilitate RICO enterprises criminal acts or
28 other valuable enterprise services against Remington and in pursuit of the Enterprises purposes and
objectives, at times.
588
1 Using a conventional and imprecise definition, which would include being a definite RICO
2 member or associate that does not do and has not done anything especially illegal or important, the
3 following names would therefore become potential non-leaders, non-criminal executors (yet) or
4 strict followers. This list which was eventually about 15 is now reduced to close to zero because
5 upon analysis, some of the more benign and passive followers who clearly are just regurgitating
6 Gans orders and probably initiating little or nothing themselves, still would appeared to be just as
7 guilty as a supervisor at Auschwitz who is merely following orders, but history has determined
8 should have not followed their criminal orders, and done something more morally correct.
9 For example, Jon Kishpaugh, Joy Mathson, Brian Gwynn, Costa, Julie McBride (Gans
10 Secretary), Peter Esko, Kloppell, Mischa Schwartz and possibly Marcy Conn were likely just
11 following illicit and corrupt orders from Gans, which does not appear to exonerate them and make
12 them bona fide passive instruments. Is committing intentional fraud or state perjury really
13 passive? See 5 pages above for more up-to-date analysis from March 2017.
14 The only truly passive, non-complicit, non-assisting, non aiding and abetting RICO
15 enterprise members, or at least potential ones that Remington can identify today include: Boyd
16 Davis Public Works Director of the City of Eureka in 1998; Mike Pulley, Paul Dalka and Mark
17 Hubbard. This group of four have a distinct, but so far non-criminal involvement here, and are so
18 passive (to date) that they are not presently named as RICO defendants, or even potential
19 defendants, at all for a variety of reasons mostly explained above, and three of the four additionally
20 involve statute of limitations issues.
21 In the special and so far unique case of Mike Pulley, discussed at length above, we need
22 further discovery as to how far he is going to to go towards corrupting himself on Gans behalf.
23 In his limited appearance in August 2016 he testified rather forthrightly, and acknowledged
24 what he did himself and what he was told to say or write by Gans and Mathson. Remington has no
25 quarrel with that. Honest facts and truthful testimony is what Remington wants and its hard to
26 commit a federal crime when one just tells the truth and otherwise does the right thing. Hence he
27 is now in the ambiguous and nebulous position of being a Gans associate, important foundational
28 witness and/or even a borderline RICO enterprise member, but one that is not yet guilty of any
crime other than by being associated with Gans corrupt organization. When questioned about his
589
1 borderline unethical extent of the fill lines on his chart, he freely admitted the truth of where he
2 got his data and that was reasonable and sufficient. Remington obviously has plenty more to say on
3 the above, and all of these named defendants, borderline defendants who are involved deep enough
4 here to be construed as RICO enterprise members, but as explained, each individual has different
5 culpabilitys here and just by being associated with the enterprise and its criminal or innocent
6 activities does not in itself make anyone guilty of anything. Therefore, Remington presently draws
7 the line of brevity, right about here.
8 Other possible or ostensibly passive instruments here might include some of the testing
9 technicians with unknown names, and inferred RICO members such as Chris Watt of LACO
10 Engineering; Mike Retzloff, Gary Evans, Harold Hilfiker, Jason Eads, Mike Foget, Kiff Analytical,
11 Cal Science Environmental and Mickee Kishpaugh.
12 For this document, those named in the above paragraph are deemed to be present or likely
13 planned future passive instrument members of Gans RICO enterprise. That temporary and rather
14 arbitrary decision today is based on our present quite limited information and discovery and the
15 fact that most of those named in the above paragraph have not yet even testified, or made any
16 statements, declarations or put any known opinions into these cases. They are all involved in the
17 cases and the majority of them have been scheduled to testify or potentially testify in Gans defense
18 to Remingtons contamination cases. Chris Watt and Mike Foget are exceptions to that which were
19 discussed above and need not be repeated here, but they are likely to appear in some capacity at
20 future trials, on one side or another.
21 6 (g) State how each defendant participated in the direction of the enterprise, from
22 2012 through January 2017.
23 The primary overall RICO enterprise directing managers are Gans, Brisso, Lawrence and
24 Olson operating through Skillings. Mathson is also an important supervisor of his local group of
25 friends, perpetrators and gang members but does little if any planning, instigating or ordering
26 without a direct order from Gans.
27 Gans is the managing, hands-on CEO, or more aptly the general with effective control over
28 his entire RICO hierarchy, and does an estimated 85% of all enterprise decision-making, although in
frequent consultations with chief Lieutenant Plotz and overall general (or Fuhrer, perhaps),
590
1 BRISSO. Although much more discovery is necessary in order to make these estimates numerically
2 valid or provable to a jury, nevertheless at this time Remington estimates that chief accomplice, aider
3 and abettor and financier, Lawrence perhaps does about 5% of any actual determinations of what
4 insidious work the enterprise should attempt next against Remington; whereas, primary active
5 perpetrators Olson and Skillings, perhaps do as much as 5% of any actual planning and premeditated
6 independent actions, and BOTH Mathsons together might initiate independent criminal actions
7 against Remington, is development and fenced property about 5% overall. In other words,
8 occasionally someone other than Gans will do something independently on behalf of the RICO
9 enterprise, but that would be RARE, especially since late 2015.
10 All of the other enterprise members,Associates and likely soon to become members,
11 including BOTH Mathsons are believed to be almost entirely non-directing passive soldiers,
12 accomplices, aiders and abettors, and a few are also major acting perpetrators, such as John
13 Mathson. These other enterprise members, associates and aspiring RICO apprentices (such as
14 Plotz) do their perpetrating usually ONLY after Gans gives orders, and they rarely if ever do
15 anything on their own initiative without Gans legal cover and protection. However, for every rule
16 there are always some exceptions. In the real world, all humans and soldiers at all levels of any
17 bureaucracy, obviously make their own small decisions, just not the big deliberate ones which
18 involve knowing and planned criminal predicate acts. It is presently beyond the scope to determine
19 which RICO decisions today would be considered small or big and deliberate.
20 However, all members of this enterprise are capable of criminal activity either by accident or
21 by their execution or association with some Gans order, response to a corrupt email or phone call
22 (wire fraud) or letter (US mail fraud), always ALL paid for by Lawrence. Obviously there are now
23 hundreds of individual complex cases and some of which may even have initially been a lawful
24 order, or a mailed scope of their intended work or research, but which work or act accidentally
25 (or on purpose from Gans cunning and deceptions) became corrupt. None of that is surprising now
26 because the vast majority of all Gans litigatory activities against Remington now in all cases have
27 become more criminal than ordinary and honest. Remington could cite numerous examples that
28

591
1 illustrate any or all of the above paragraphs, but will wait until requested by the court or other
2 necessity, in the interests of a semblance of brevity here.46
3 7. State whether you allege, and describe in detail how, Pattern of racketeering the
4 pattern of racketeering activities and the enterprise are separate or have merged into
5 one entity.
6 A. Occasionally, for very discreet and limited periods of time such as during a jury trial, the
7 briefly publicly conspicuous pattern of continuous racketeering activities may merge briefly with
8 the enterprise into what appears to be one entity for a few days or weeks. Otherwise, the basic
9 answer to the question is that the enterprise and racketeering activities are mostly separate and
10 not merged, as detailed more precisely at B. below. Probably the main reason for that is because
11 just like a mafia family, even the worst RICO enterprise does not do 100% continuous illegal acts
12 and has a life of its own similar to any type of horrible monster, from literature or cinema. Even the
13 worst killing monster which maims tortures and mutilates human beings, always has its softer side
14 and back story, and other Non-criminal activities which it does such as gathering food for its family
15 and protecting its young from outside forces. In other words, without getting overly philosophical
16 and lengthy, even the worst evil Nazi, for example Hitler, always seems to have a presence, entity
17 or set of other activities which are distinct from the criminal enterprise which may commit
18 thousands of federal predicate acts but never does so continuously.
19 Rather obviously the above are separate because in this ongoing complex litigation
20 involving five (5) different cases now with only one apparently fully over, that leaves three (3)
21 which remain in their entirety (DR080678, DR140426 and THIS case) plus a fourth, the 2009-11
22 federal case (CV 09 4547 NJV), which is just as alive as ever, due to the frivolous application of
23 collateral estoppel by defendants and now by Judge Reinholtsen. Very arguably, that technically
24 decided summary judgment in CV 09 4547 NJV, confirmed by the Ninth Circuit, is the most
25 important, influential, unjust, prejudicial and presently deleterious influence on all of these three (3)
26 other cases today, all the way into March 2017.
27 46
For more detail and sophistication regarding the definitions used here to distinguish the functions of the
various types of RICO members, from perpetrators to passive instruments and support personnel, please
28 refer again to the well-researched standalone single-spaced six pages beginning on page 556 above: 5. (4)
Theoretically and actually which RICO members here were perpetrators, aiders and abettors, and
accomplices, and what are the relative culpabilitys of each in this case, and why?
592
1 This issue however is quite complex philosophically and there are so many exceptions or
2 variations and/or qualifications needed for most generalizations about this that a few pages here
3 cannot fully resolve all of the related issues, exceptions, definitions and qualifications required to
4 fully answer that question in a legally rigorous manner.
5 One reason for that is that Each of the above named Remington-defendants litigations, have
6 had some defendants filed corrupt documents, fraudulent objectives and statements intended to
7 deceive Remington and the courts, and therefore one or more state or federal predicate acts or
8 related frauds were committed within virtually every defendants file document. However, also in
9 every document in virtually every case usually, as much as 80% of defendants lawyers work was
10 legitimate and arguably mostly based on case law and the Code of Civil Procedure. Obviously,
11 many exceptions exist in all directions as to the percentage of legitimacy and fraud in the various
12 documents, hearing remarks and related activities in all of these cases over almost 9 years now.
13 So, does 80% ethical work make it right? If you invite 10 people into your office and only kill
14 two of them that means you did 80% ethical and legal work! That is an entirely appropriate analogy
15 here and is merely another way of exemplifying the fact that a RICO enterprise can still be corrupt
16 enough to warrant a death sentence for its top leadership and other culpable perpetrators, while
17 simultaneously doing 80% exemplary, honest and charitable activities.
18 Again, the basic point here is (as much of this discussion was written four months apart), that
19 even a criminal murderer or a Hitler-like dictator does not perform 100% illegal acts all day every
20 day and may only commit one murder a month or may be only one every 10 years, however that
21 person is still a murderer and potentially a racketeering enterprise member in a case such as this
22 one. In other words, you dont have to be a mass murderer, continuously murdering people every
23 day as in a Nazi German gas chamber for Jews to warrant a grand jury indictment for only one
24 murder, or as in this case 50 other federal crime violations, which although not murder,
25 cumulatively may add-up to perhaps the equivalent of several murders, but perhaps more
26 acceptable types of murders in this rather coarse and nasty 21st-century society, i.e., murders of
27 older people, or other less desirable people to society, which definition is changed a lot in this
28 country under the current 2017 U.S. presidency.
In other words, lawyers fully control, operate and run this enterprise complained of herein on
593
1 a day-to-day basis, and lawyers must follow standard lawful document formats, meet continuous
2 prescribed deadlines and follow many of the conventional California rules governing civil
3 procedure, and Gans enterprises lawyers and leadership do exactly that. Even Gans incompetent
4 and corrupt experts reports, declarations and objections to Remingtons evidence are not 100%
5 fabricated, but perhaps only 20-30%.
6 However, just because most of your motion documents are ordinary, honest and drafted to
7 proper administrative CRC guidelines, does not make the overall document or its purpose ethical,
8 proper and immune from criminal indictment, if the 20% objected to here is provably corrupt and
9 criminal, as we think nearly all of Gans and Plotzs 2015-17 documents are.
10 Additionally, in order to operate seamlessly, without suspicion from court clerks and judges,
11 and without undo friction in the California legal world, a good pretense and perfect appearances
12 must always be kept-up in dress, speech, length of hair, punctuality, document format, content and
13 timeliness, and Gans must above-all accurately and seamlessly simulate ALL of the above, in all
14 respects, and at all times appear to be an ordinary, normal, honest and prototypical attorney.
15 Gans and all of the Mitchell attorneys do that very nicely, but it is a circus act. Its not even exactly
16 a well-rehearsed act, because Gans can seamlessly fulfill the role, because he probably was an
17 ordinary and legitimate attorney for 5-10 years before he got involved here over his head, and
18 beginning in late 2011. When Gans defensive strategy began crumbling and failing in dozens of
19 ways, he was desperately forced to write perjury for ALL of his trial and declaring witnesses and
20 also began to falsify all of his Blue Rock experts results and conclusions as early as 2010, which he
21 did flawlessly and without suspicion by us or any sort of significant detection for several years,
22 although they definitely didnt do corrupt acts from 2008-2012, just not enough to cause serious
23 scrutiny, especially in a pro per litigant. Even Remingtons Farmers attorney Harvey Roberts was
24 often surprised and occasionally aghast, but did not really go almost speechless and become
25 incredulous until spring 2016, when his formal role had been exhausted (as explained) and all he
26 could do was comment informally, but with great surprise.
27 This court will presumably eventually conclude, as it took Remington about eight (8) years to
28 do so, that Gans is not honest, not real, barely human (despite pretty convincing pretenses to the
contrary), is not a lover of the law, sees the law as an instrument for himself to abusively use like a
594
1 mask and a bludgeon; plus, it also serves as a full disguise, in order to help him accomplish illegal
2 acts, under the color of law and respect therefore, all of which false pretenses are now exclusively
3 in furtherance of his enterprises objectives. All of Gans unlawful RICO objectives were set by
4 himself, to make himself a huge amount of money from these cases since 2007, and hence Gans
5 now exclusively pursues his own entirely selfish usury and career-advancing objectives, while only
6 very occasionally mentioning the Mathsons anymore.
7 Altogether, it is quite complex and somewhat confusing to attempt to write, on simple
8 straight-forward topics like deposition scheduling or negotiations to settle his Mathson case DR
9 080669, Gans was rather straightforward, although he slyly used maximum leverage (which
10 Remington has elsewhere characterized as mild-extortion directed towards Farmers Insurance), to
11 fully accomplishes second most coveted objective which was to force Farmers to remove
12 Remingtons attorney and primary life-line, Harvey Roberts, from the case and also to pay
13 Mathson twice as much as what Farmers wanted to pay, and had offered. Simply put, as fully
14 explained above, that whole negotiation was always really only about removing Harvey Roberts as
15 Remingtons only legal assistant to both sides. As fully explained, Farmers was very very
16 obviously only too glad to pay only $20,000 to Gans and defendants in order to avoid very clearly
17 and obviously foreseeable payments to Roberts of a minimum of $100-150,000, and/or very
18 foreseeably total possibly and foreseeable payments of as much as $1 million.
19 Gans operated very aggressively from 2008-2011 and then progressively more unethically
20 beginning in summer 2011 in the federal case. Even when Gans won some Rule 26 and Rule 37
21 federal battles, that was never quite enough and therefore he had to and DID misrepresent and lie
22 about meeting and conferring with Remington on various motions. During all of summer 2011,
23 Gans never met or conferred with Remington about anything and lied about it; and, thereafter he
24 successfully deceived the federal magistrate, which deceptions and fraud on all courts is Gans
25 utmost specialty. Gans failures were not just inconvenient minor irregularities but were serious
26 violations of federal laws, federal local rules and Judge Vadas personal local court room rules. Had
27 Remington been able to prove that, Gans defense would have been dismissed and all the cases
28 would have ended in Remingtons favor. In other words, what Gans failed to do was serious and
therefore he had to lie pretend that he had properly met and conferred with Remington on the two
595
1 major case ending motions. Gans had to lie to save face and credibility with Judge Vadas, and since
2 Gans loves to lie, and is extremely experienced at it, he therefore blatantly lied seamlessly, naturally
3 and apparently without any remorse.
4 Therefore, the more that Gans was losing, or perceived that he was not winning an immediate
5 and conclusive victory, the more unethical he became beginning in fall 2011 with his entirely false
6 and deceptive summary judgment motion documents, and then followed-up that with his fraudulent
7 deceptions and mischaracterizations during the reconsideration motion proceedings. Beginning in
8 2012 and continuing into the Ninth (9th) circuit appellate process, Gans was again terribly corrupt
9 to deal with, and during the entire process, Remington would again estimate that the above
10 approximate ratio of Gans written ethical to false representations continued at about 80% ethical to
11 20% fraudulent, false and/or perjury. Again, we ask rhetorically as above, do 80% proper, ethical
12 and ordinary good-faith activities during a day or in a written document make up for or fully
13 compensate for 20% that are false, corrupt and which directly and flagrantly violate specific
14 federal laws?
15 One good example of the first sentence in the above paragraph was when Gans stupidly took
16 an unnecessary and very complex second deposition of John Aveggio, in order to go over the 100
17 most important case issues at that time and attempt to get Aveggio to make his entire defense for
18 him on each issue. That lazy and stupid Gans idea backfired totally and instead of refuting even
19 one of Aveggios profound and brilliant opinions on said 100 important case issues, he made a
20 conclusive sworn record from the great Aveggio before his death, which now cannot be assailed and
21 will eventually easily lead to Remington winning his cases at the next contamination trial.
22 Therefore, what happened on July 1, 2011, was that Aveggio was much too smart for Gans,
23 and also Aveggio had all of the honest and true facts on his side. Gans had nothing but false
24 science, bad experts, prejudicial speculations and no actual admissible evidence to refute our testing
25 evidence with, because Gans was always too afraid to do any testing on Remingtons land, because
26 it was by inspection and obviously as based upon all of the senses clearly contaminated.
27 The more Gans tried to confuse or refute any single salient case issue, the more crucial
28 evidentiary ground Gans lost. Aveggio proceeded to refute every single important case issue which
Gans asked him about and ultimately made Remingtons entire case as solid as it is today, even after
596
1 Aveggios untimely death. But for that death, these cases wouldve been over many years ago,
2 however Gans memorialized Aveggios brilliant work for all eternity now in his brilliant
3 Deposition Number Two and eventually that will be the one deposition to many which loses
4 all of these cases for Gans.
5 A. The 2009-14 Remington v. Mathson federal case is still of critical importance today in
6 this court because Gans has deceptively and improperly invoked collateral estoppel from that case
7 to the state cases and by extension to this case.
8 Again, by way of brief summary of the 2009-14 federal case, Gans took an innocent good-
9 faith Rule 26 expert disclosure failure by a careless pro per (Remington) and milked-it into a total
10 technical summary judgment against Remington by twisting his actions and motives, plus some
11 well-timed perjury, alluded to above.
12 After confusing and deceiving the federal magistrate about Remingtons lack of expert
13 disclosures in the federal case because they had been so thoroughly disclosed in the state
14 cases, and lying about the lack of prejudice caused thereby, NEXT, Gans improperly disclosed
15 his own scientific experts and then got away with using them anyway to conclusively get
16 Remingtons entire case dismissed. Several experts were involved, however the most crucial was
17 Schwartz on asbestos who was disclosed about four months too late BUT was then used to
18 conclusively confuse the magistrate and all subsequent judges by refuting Remingtons asbestos
19 claims, which had no expert support after Gans deceitful use of Rule 26.
20 Gans even cleverly managed to trick the magistrate into allowing him to use Remingtons also
21 improperly disclosed expert Aveggio, who was not even in the case at that point, against
22 Remington, regarding Aveggios deposition testimony about imminent danger, to very
23 successfully confuse and trick the federal magistrate into dismissing Remingtons entire case.
24 Although, this is somewhat complicated, and without explaining everything mentioned above: First,
25 Gans managed to crucially and conclusively tricked the magistrate into removing Aveggio from
26 Remingtons case entirely, leaving Remington Mortally wounded and only minutes from death,
27 with no experts admitted into the case to present evidence in a contamination case, where
28 environmental experts are beyond crucial. But then secondly, even though Aveggio was barred from
Remingtons case and from all proceedings in that Federal Court, Gans very unethically and
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1 unlawfully used Aveggios 100% barred deposition testimony on one RCRA issue (The original
2 pronouncement of no imminent threat to health and the environment, which opinion was revised
3 about one month later) against Remington! The magistrate unjustly prevented Remington from
4 using Aveggio, his own expert, but then allowed Gans to use them to seriously damage
5 Remingtons RCRA case! That gross injustice in itself should be taken into consideration in this
6 court now.
7 To Remington, that seemed unfair then (and still): Namely, that his only important
8 contamination expert (Aveggio) was prejudicially 100% barred from his case, however when Gans
9 improperly used that testimony against Remington in his summary judgment documents, the
10 magistrate did not have any problems with it, and in fact cited to that improper evidence as he
11 dismissed Remingtons case, just as it also extensively quoted Schwartz, who was not properly
12 disclosed as an expert in the case either.
13 In other words, nothing was too improper or unethical for Gans and everything that he
14 requested was granted and then some, whereas the magistrate without any hearings whatsoever, and
15 without any examinations of or knowledge about Remington whatsoever, still decided that Gans
16 enterprise was correct in everything which they requested; and, conversely Remington was wrong
17 and was the bad guy that should be relegated to the overcrowded Humboldt State courts.
18 Simply put, having no Aveggio at all, and hence no environmental expert at all to back up his
19 federal statutory claims, instantly killed Remingtons case on technical grounds only, but to make
20 the whole situation even more unjust, the magistrate allowed Gans to use both Aveggio plus his
21 own improperly disclosed expert, Schwartz..
22 Remington had in 2009-14 and still has a fine federal and state case, but without any admitted
23 environmental experts to back it up, that case instantly becomes meaningless, and has led to the
24 present unjust situation we are in here today, and this present confused stalemate.
25 Therefore, as outlined, Gans litigation behavior was increasingly unethical, and he violated
26 several federal criminal codes back in 2008-2011 or earlier, but not enough to complain about
27 excessively here, and since they occurred more than four years ago, Remington is waiving them on
28 statute of limitations grounds, in the interests of avoiding complex litigations thereof. In any case,
there was no noticeable RICO pattern of racketeering activity back in 2011 nor was any organized
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1 RICO enterprise as described herein distinct or adequately defined back then. Arguably, Gans did
2 not need a RICO enterprise to win these cases back before 2011 or at least thats what he believed,
3 however since then everything is changed and during 2016 Gans became totally desperate, ruthless
4 and unscrupulous in his trial coaching and suborning of perjury, and Remington intends to make
5 sure he does not get away with that, or personal reasons and also as a beneficial service to this
6 community. Clearly the roots, introduction and corrupt will, etc has been available, present and
7 projected by Gans at various times since 2008, however he did not put it all together coherently into
8 a tight, clearly defined and well-organized RICO enterprise, until after 2012.
9 As above, Gans is inherently lazy and corrupt in his basic nature. Hence when he loses
10 something he becomes increasingly desperate to win, because he never had a viable scientific
11 defense from the very beginning; therefore, because he never had any useful conclusively rebutting
12 evidence or any competent experts reports to use in his defense, when the going gets tough and it
13 looks like he is going to justifiably lose this case, he naturally gravitates towards manufactured
14 testimony, which here means subordinating perjury. Those tendencies were there all along, but not
15 dramatically noticeable or continuously obtrusive and dominating until the numerous late 2015
16 motions and hearings merged into the extensive 2016 depositions, evidentiary, jury instruction and
17 expert motion hearings, and then the extended hundred plus days of pretrial hearings and the August
18 2016 SOL trial.
19 We will need extensive discovery to prove it, however inferentially Skillings and Olson
20 became highly impatient with Gans slow 10-year litigation process in 2012, and then obviously
21 panicked when Remingtons expert remediator and excavator operator Figas showed-up on
22 Remingtons land a distant 300-feet away from defendants contaminated waste dumps, with his
23 massive machine and actually did substantial other work for Remington before being abruptly and
24 surprisingly scared-off. Therefore, after those well-described intimidations and extortions of Figas
25 from about December 2012 into at least May 2013, the RICO conspiracy and structure that we can
26 see clearly today was formed, but again was quite invisible, clandestine, not obvious, and easily
27 avoided detection by Remington and the courts, neither of the latter of which had probably ever
28 seen or understood RICO previously.
The latter were the only ones capable of possibly detecting Gans enterprise sooner, however
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1 Remington did not have any idea what a RICO enterprise was until August 2016 when he read
2 about them with great interest and for the first time in McElhaneys Trial Notebook about the
3 relatively common, but totally unethical, barred and corrupt Federal law violating lawyer
4 practice of wood shedding and coaching witnesses to swear to false narratives, drafted by
5 crooked attorneys, such as those named here. McElhaney then cited 1961,which was the first
6 Remington had ever heard of that and about six (6) solid, mostly uninterrupted months later here we
7 are. Remington realized during the August 2016 SOL trial that he had been steamrolled, abused,
8 sandbagged, raped and plundered unjustly, and nearly killed by something big, evil and powerful,
9 running him over with a massive, unseen machine of some sort, and then with the drivers of that
10 evil machine jumping-out of nowhere to bludgeoned him to death, which after a lot of legal
11 research and thought, eventually led quite directly to these proceedings.
12 Gans, Plotz, Brisso, Kluck and Mathson, et al were really clearly loving their work,
13 dishonesty and perjury on the only material issue in the August 2016 SOL trial, and it now has
14 become 100% positive that Gans cannot defend and WIN any of these cases on the honest facts
15 and merits, which makes Remingtons job a lot easier, and now just merely involves proving
16 perjury by one or more of Gans MANY lying witnesses. Gans has unleashed Pandoras box in
17 effect and once the evil, corrupt lies have fully enveloped and deeply and totally absorbed into all
18 surfaces of Gans defenses, there can be no going back to old-fashioned honesty and integrity, and
19 now its just a question of Remington hanging-on and putting all of the facts together into a More
20 concise and coherent whole which a judge, a jury and he himself can easily understand.
21 There is no way that all of that perjury can now hold together consistently, hence as
22 expressed frequently above, it has become mostly a question now of which cracks in the foundation
23 will crumble completely and who will be caught in the ensuing collapse of the enterprise, and who
24 may possibly escape in time.
25 B. Therefore, the generalized conclusion as to question #7 is NO.
26 Gans enterprise and pattern of racketeering activity has still not fully emerged into one corrupt
27 entity, and hopefully never will. To become one corrupt entity for a 30-60 minute period that
28 would probably involve about 10 RICO perpetrators breaking-down Remingtons fences and gates

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1 and then attacking and assaulting his house with rifles and firebombs, with the purpose of burning
2 Remington out of his house, and then shooting him when he emerges.
3 As long as Gans legal deceit and general corruption of the judicial process continues at least
4 moderately successfully, probably Gans will not need to resort to direct violent attacks on
5 Remington. As explained, the above corruption is mixed-in with a majority of reasonably legitimate
6 legal activity which requires rigorously structured documents and pseudo-civility, which so far has
7 kept the enterprise from following Skillings or Mathsons leadership and becoming something on
8 the order of a violent Murder Inc. Remington might be the first to go, however he has a variety of
9 experts and others, which are not specifically named here to avoid them becoming secondary
10 targets, plus four (4) highly competent immediate family members (with both the will and/or
11 exceptional legal competency in the case of two of said members), which are perfectly capable of
12 proceeding with these lawsuits as subsequent events may require. Hence Remington is not entirely
13 alone, nor is his just case dependent solely on his survival. Ultimately, justice will prevail here, with
14 or without Bruce Remington enjoying a renewed and remediated pristine environment here again,
15 as it was in 1980 when Remington began his development here.
16 Perhaps all that is important now is that if anything DOES happened to Remington then
17 everything written here in this lengthy statement will have a lot more significance and meaning to a
18 lot of people and justice will eventually be done, without a doubt. For example, public interest and
19 interest by criminal authorities would likely go from about 2 to about 95. Exactly who some of
20 these sentences and statements are directed to will be apparent to the corrupt individuals, and also
21 further clarified imminently in discovery, so Remington does not need to interject any further
22 subjective opinions and/or paranoia herein.
23 Additionally, and probably happily, Gans is still rather civil, devious, kind of a stodgy,
24 overlay-nourished pussy, and so far is merely a well-established but highly competent white-
25 collar criminal. Like Olson, he is rather creative and probably he is a somewhat unique in his
26 criminal ingenuity and they both probably have the ability of only about 1 in 100 in their trades or
27 profession to turn an honest vocation into a much more lucrative dishonest one. Gans presently
28 appears to leave virtually all of the dirty work and perpetrator-stuff to John Mathson, Skillings,
Kishpaugh, Randall, possibly Plotz and to other members of Mathsons Westgate gang. On the other
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1 hand, Remington is not completely positive of that because Gans has entirely tricked and deceived
2 Remington on very material matters several times before.
3 Gans has also appeared several times on surveillance video at disquietingly frequent
4 intervals, without any notifications or formal investigations of Remingtons land, and he spends
5 more time hanging-around the Remington-Mathson border and agreed fence than Remington is
6 really comfortable with. Gans also always comes at about 8-8:30 AM because he knows that
7 Remington has virtually never been here in 36 years before noon. Therefore, at 8:30 AM Gans,
8 Mathson, Plotz and all of them who have appeared so far on surveillance videos (about at least
9 another dozen have been around here), are absolutely free to break down Remingtons fences, go
10 through Mathsons secret doors or otherwise invade Remingtons property at will in the early
11 morning, knowing that Remington will never be here to photograph their trespassing or call the
12 Sheriffs. Remingtons quite extensive 100s of surveillance videos, over several years, prove that
13 they do exactly that.
14 Gans and Plotz throughout 2015-16 still mix in their corrupt illegal activity with their
15 attempted civil intimidations and extortion by requesting severe monetary sanctions against
16 Remington in every single motion or opposition which they file in these cases. There have been
17 numerous examples in only the last year, and it is just their routine now for defendants to always
18 request sanctions of $2-3000 or more, whenever they oppose any Remington motion, which is
19 frequently, or when they file their own motions which Remington opposes. Obviously they dont
20 like anything that Remington does in either case, or under any circumstances, however fortunately
21 none of the last four (4) judges that have issued decisions in these cases, have paid any attention to
22 those continuous sanction requests. Judge Reinholtsen who has heard the last 5-6 sanction requests
23 now just ignores them in his written orders, as though they are ridiculous and unworthy of comment
24 even, and after getting rather agitated and defensive about it for many years, Remington also now
25 just ignores them as frivolous, ridiculous and totally without merit. To Remington, that seemed
26 unfair: that his only important contamination expert (Aveggio)
27 Defendants sanctions requests are still unjustly irritating, mildly upsetting, but now have
28 become very obviously frivolous to every judge involved in these cases, for the last 5-6 years.

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1 Hopefully that will continue here when defendants request sanctions against Remington for every
2 federal motion he makes, starting with this one.
3 Therefore Remington has saved himself probably $15-20,000 in the last few years by opposing
4 or recently now just ignoring those stupid and frivolous sanction requests on the last pages of
5 Plotzs every motion document. To Remington, this is a pretty important issue because litigating for
6 the last 10-years and not properly conducting his business in the meantime has pretty well bled
7 Remington dry financially, with several hundred thousand dollars of related expenses, costs and
8 direct monetary damages caused by this lengthy litigation. Defendants know that their best and
9 probably only possible successful tactic would be to force Remington to give-up these cases due to
10 lack of money. That will never happen, but it is always a potential danger in the background if
11 something catastrophic were to occur here, or in the investing world.
12 Remington has not yet sought legal authority specifically as to whether defendants continuous
13 frivolous sanction requests and incessant multiple threats of suing Remington for malicious
14 prosecution and vexatious litigation, slander, abuse of process, contaminating Mathsons land,
15 and many other related unfounded allegations are actual extortion, intimidation, actionable threats
16 or whether the RICO enterprises large legal team with their considerable anxiety-causing threats
17 are all just an acceptable if rather extreme extension of the normal California legal process. As it is
18 today, Gans enterprises legal team opposes Remington with at least two full-time attorneys and at
19 least one full-time secretary and paralegal, whereas Remington has no employees and types, word
20 processes, dictates and/or edits every word in his documents himself, personally.
21 In due course, Remington will look further into this frivolous sanction threats as extortion
22 issue because it is clear to him that Gans and Plotzs above continuous frivolous sanction-threats
23 and related threats of malicious prosecution and vexatious litigation, etc, are merely another form of
24 intimidation and extortion in order to further Gans RICO enterprises stated objectives above; but,
25 whether cumulatively they are another predicate act will be left for another time, or for this court to
26 summarily determine, to the extent that it was presented under the 18 USC 1951 allegations.
27 Additionally, as per some of the hundreds of pages of notes written back in October-November
28 2016: Remington would argue today that each frivolous sanction request often to a potentially
biased visiting or locally inferentially bribed judge, is a realistic danger and fear-provoking unjust
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1 act which is nothing more than a white-collar shake-down attempt and further extortive activity
2 analogous to a frivolous special motion attorney fee demand. One such partially bogus and
3 fraudulent special motion was filed against Remington in 2008- 2009 which was partially granted
4 by Judge Miles as discussed above, but only after reducing Gans and Brissos substantially
5 frivolous attorney fee requests, by at least 80%. Arguably, nearly all of their fee requests were
6 reduced and/or nearly eliminated completely because Brisso conceived the endless moneymaking
7 scam, like the goose that laid the golden eggs, of adding-to his attorney fee request every minute
8 that he spent opposing Remingtons documents or preparing his own sloppy requests and replies,
9 plus the time of attending hearings and walking back and forth to them. In other words, the harder
10 Remington fought and the better arguments he made to refute defendants false and inflated
11 attorney fee requests, the more money Brisso added at the next hearing, with apparently no realistic
12 end in sight.
13 Since Gans and Brissos initial requests were largely fraudulent, padded, fabricated,
14 exaggerated and double-billed, and required considerable time and analysis to prove all of that,
15 potentially that dispute could have continued on for many (MORE) months or years in the event of
16 an appeal, and accrued another $50-100,000 of fees.
17 Happily, Judge Miles listened to Remington rather early on, saw that his positions were just
18 and well-taken, and also caught-on to defendants rather quickly: First, to Gans total dishonesty
19 and false statements about his wages costs and other expenses incurred in preparing a simple form
20 document which obviously only required 5-6 hours. Her anger and disgust with him was
21 immediately sufficient to humiliate him sufficiently that he never returned at all in several months
22 to continue arguing his attorney fees, and thereafter left it entirely up to Brisso to mop-up. Second,
23 she focus on Brissos deceit, dishonesty and attempted fraud upon Remington and her court, for at
24 least three consecutive hearings and quickly got very unhappy with Brissos presentation also, after
25 a couple of months. Eventually, she rejected approximately 80% of their total past and future
26 fraudulent monetary demands, and to Brissos chagrin, she did not give them one more dollar for all
27 of their continued hours of defense document preparation, for Brissos last 3-4 hearing appearances.
28 Cumulatively, what defendants did there was dishonest, very unethical and would have been
considered to be criminally corrupt if this was a bank involved in this kind of attempted extortion
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1 and embezzlement. However, since it preceded the statute of limitations in this RICO case, it is only
2 cited here as background and as a reference on the RICO enterprise leaderships overall integrity
3 and prior track record.
4 As further important background, but without getting into excessive and extraneous detail,
5 there was also a second special motion in 2009 submitted to Judge Reinholtsen, which was entirely
6 based on a confusing and intentional fraudulent misstatement of two case issues which Gans
7 jumbled together, totally confusing Judge Reinholtsen. Said Judge stubbornly will never
8 acknowledge his confusion about anything, or ever reconsider any decision that he makes. In this
9 instance Gans deceit and deception, combined with Judge Reinholtsens refusal to consider that he
10 might have been deceived or to reconsider a pretty simple deception and expensive error to
11 Remington, which in this case led to another $1900 special motion assessment against Remington.
12 The substance of that motion has been discussed elsewhere in these documents and in several other
13 recent 2016 state pretrial documents, of which defendants are very well aware, and in any case the
14 details of that issue are not especially relevant here, and can be next relitigated it in state appellate
15 court. Summarily put, Gans deliberately equated two very different contracts and agreements
16 between Remington and Mathson about four years apart, and falsely declared that they were one
17 and the same and hence violating the litigation privilege and/or settlement agreement law. That
18 false identicality issue is a common theme with Gans and was the same false identity which he
19 made in his collateral estoppel arguments wherein he said the issues in the federal statutory case for
20 identical to those in the state contamination case, when Remingtons comprehensive, detailed
21 written and sworn analysis showed several hundred issues, not one of which was identical between
22 the two cases.
23 Judge Reinholtsen unfortunately did not have, or take, the time to fully understand the issues
24 in 2009 or really at any time since then, nor did Remington present them clearly enough orally at
25 the hearing, 5-6 hours earlier than his normal working schedule, so he has to share some of the
26 blame for said judges lack of understanding. That was an early example of Judge Reinholtsen
27 giving his former law partners the decided benefit of the doubt against an obnoxious pro per
28 litigant, but there were several years after that where Judge Reinholtsen ruled 80-90% in
Remingtons favor, on at least a dozen consecutive motions, until that mysteriously diametrically
605
1 reversed in the entirety of 2016, and arguably about 100 important decisions all went against
2 Remington, two or three per day.
3 That additional fraud by Gans has been complained of ever since then in federal documents
4 and elsewhere. It is irrelevant here except as background because it occurred well outside of the
5 statute of limitations, and in 2009. Furthermore it will be eventually appealed in the state courts and
6 Remington has no doubt that clearly and concisely presented, it will prevail there. It is referenced
7 here because it does show that Gans unethical litigation practices and/or gray-area criminality and
8 frauds on both Remington and the courts, has been going on for quite a while. When the district
9 attorney, FBI, grand jury and/or other criminal investigations begin here, it is expected that these
10 illicit, unethical and/or corrupt litigation practices have provably gone-on for many years years in
11 most if not all Gans other cases, however Remington does not have time now to investigate that
12 and may never have the resources to do so. He will however find the last dozen attorneys that have
13 opposed Gans in trials or hearings and share experiences, stories, witnesses, problems and advice.
14 In summary, it is clear that Gans is rapidly moving his enterprise into increasingly more
15 criminal activities since 2015, but most of the named enterprise leadership, soldiers, direct
16 perpetrators and other associates are probably not yet aware of all of their criminal associations, and
17 at least some of them will be surprised when they read this. Surprise is fine, but now everyone
18 named herein has been put on notice to investigate the truth or lack thereof of Remingtons
19 allegations and at a minimum should diligently question Gans and Plotz about what they have done
20 previously and whether they intend to repeat their state felonies in federal court where penalties are
21 much more serious as described. Suggesting getting real and independent legal advice when
22 Remington himself is in Pro per would be inappropriate, but obviously it would be a conflict of
23 interest now for any Mitchell firm member to counsel or provide any legal advice whatsoever, to
24 any named RICO defendant or other associate, and undoubtably all RICO racketeering members
25 will figure-that-out for themselves almost instantly.
26 All named RICO defendants are NOW, if not for the prior 7-12 months, fully aware of the
27 criminal nature of Gans enterprise. During trial and discovery Remington obviously Canon will
28 provide 2-10 examples of every generalization that he makes in the following sentence or
everywhere in these documents, but declines to do so at this time.
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1 Suffice it to say that all of the named RICO racketeering enterprise defendants and other
2 named participants herein, all appear to be: Enjoying it, laughing and taking the big money with
3 total abandon, they are certainly not worrying about what illicit and corrupt methods they must use
4 to defeat Remington, and are possibly oblivious of the federal laws that they are violating under
5 Gans supervision and what the penalties are if, and when, these allegations are fully proven.
6 However, it would strongly be advised to FIND-OUT about RICO on the internet. Learning about
7 RICO can be accelerated into several solid days but takes many solid months, full-time, to fully
8 grasp.
9 Also it is likely that most of the individuals named in these documents are probably not aware
10 of the large number of RICO members, associates and associated small groups and businesses
11 which Gans has put together here, NOR how very risky their involvement is here right now.
12 As often explained above, If only even one of them cracks and decides to tell the entire
13 truth about: This racketeering enterprise; about Gans and the Mitchell firm associates; what Gans
14 has written for them and then decides to fully and honestly explain to investigators what he
15 improperly and corruptly coached them to falsely testify about, swear to or otherwise fabricate in
16 order to defraud Remington and improperly when these litigations, then the imminent collapse of
17 Gans entire house of cards is nearly at hand. It may be sooner, in 2017 or maybe later by 2020, but
18 eventually it will happen, whether can soldiers get to and silence Bruce Remington or not. If
19 so, others will take over, and these documents will provide a good map about what to look for and
20 who to look at.
21 Needless to say, Remington has relatively well-formed and evidentiarily-based opinions about
22 all 33-40 enterprise members and associates of all of the types described, and what they know or
23 should have known about Gans criminal racketeering enterprise. Some of that was described with
24 particularity above. Because of Rule eight (8), we will not discuss all of that again here, however
25 those that have submitted sworn declarations in these cases or have testified under oath at the 2016
26 trial so far, are as a class far more guilty and culpable than many of the others who have not been
27 specifically coached yet as to the untruthful and un-factual trial testimony that Gans expects,
28 DEMANDS and needs from ALL of them. It can be said generally and with nearly entire certainty
today in mid-March 2017, that anyone that has ever written a sworn declaration requested by or
607
1 authored by or influenced in any way by Gans in any of these Remington v. Mathson cases, is
2 almost certainly in a lot of trouble. That is because there is almost certainly at least one fraudulent
3 false fact sworn to in every Gans associated declaration, and most have closer to dozens of errors,
4 mischaracterizations and perjured statements, and when those are transferred into federal predicate
5 acts during written and oral discovery, and at a federal trial, serious ramifications are likely, as
6 Remington has attempted to explain, based upon the US Supreme Court RICO interpreting statutes
7 and precedents above and in the thousands of pages of supporting books, documents and other
8 written materials which are part of these supporting files, but are not yet written herein.
9 Remington could write about 50 more pages on this topic right now, but needs to get this filed,
10 so he will defer on that until the next one-two years of discovery when many additional exact facts
11 will be known, and one or more key witnesses will most likely crack and decide not to put
12 their freedom and fate in Gans, Lawrence, Plotz, Mathson, Skillings and the other identified 35 or
13 more other strangers that they have never met. Quite soon we will have better documented,
14 inviolable and admissible factual, material information about: Who knew what when; who lied
15 about what and when, or was planning to follow Gans explicit orders and lie in or after August
16 2016, but either decided against it or in the one important case cited above several times, just got
17 lucky and was not called by either Gans or Remington. ALSO, and probably most importantly we
18 will soon know, and before very long, the exact name of the RICO racketeering membership who
19 are going to simplify, shorten and break-up this criminal racket in 2017; Rather than 2-3 years later
20 after two more years of perjury and the other cited severe federal law violations which will
21 accumulate exponentially during discovery here. It is a truism that is widely known in domestic
22 and international racketeering law, that telling the truth as early as possible during an
23 investigation leads to lighter sentences and in special cases, a truthful confession could possibly
24 lead to a total dropping of criminal charges against a defendant, which charges otherwise could
25 have easily been proven, in order to gain the conviction of a more culpable criminal leader, which
26 in this case could be any of the 12 named RICO defendants. Everyone nowadays understands how
27 this works: By telling the truth now, and perhaps implicating one or more of their co-conspirators
28 at that time, or possibly only Gans, John Mathson, Plotz, Brisso, Lawrence or Nelson, the hope

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1 would be that they could thereby exonerate themselves, at least in part. However, two years with
2 the possibility of probation is certainly preferable to 5-10.
3 C. Conclusions as to #7.
4 Gans RICO enterprise is getting increasingly more corrupt, but today is still no more
5 than 30-50% unlawful overall, at least on average, in all of their related litigation, criminal
6 and other activities directed against Remington and the Burl Tree, which involvement is
7 necessary by definition for this complained of activity to be RICO generated.
8 As we analyzed at some length above, thats not surprising because even a Mafia family such
9 as Don Corleones ( in The Godfather film) has plenty of honest dealings, honest leases, honest
10 food purchases, people paying ordinary rent, or wives and children living at home trying to lead
11 entirely normal lives mostly oblivious of the horrible crimes being committed all around them, or
12 perhaps a mile or two away.
13 Specifically applicable here: Defendants sometimes file entirely or mostly honest motions
14 and have also been specifically observed to have some inferentially ordinary and honest
15 interactions with various people, at the courthouse, in the community or in their ordinary non-
16 Remington combating lives, when said RICO leaderships or lower echelon mafia soldiers and
17 other members may randomly cross paths with ordinary honest people, on a given day. That might
18 be deceptive, and it could be acting as in the case of a spy transferring top-secret information to a
19 Russian agent, however for the most part Remington assumes and believes that it is genuine and
20 that even the worst criminals and mass murderers have a large number of ordinary noncriminal
21 interactions in a given day. In other words, it is somewhat of a truism or clich to conclude that no
22 RICO organized crime organization is 100% corrupt. Even a mass murderer of Jews at Auschwitz
23 makes some honest purchases, may sell something or even could hire or use honest people, who
24 have not yet been corrupted, such as when Gans first encountered, hired and then entirely
25 duped Ryan Plotz when he first got off the boat and enthusiastically arrived with eager
26 anticipation at the firm in about May 2014, as young and inexperienced as they come.
27 Remington has watched Plotzs career and progression rather closely, and with mild interest,
28 and believes that it took most of that first year before he noticeably went BAD, criminally and
personally (from the heart), as opposed to just copying Gans repetitive and familiar unethical
609
1 allegations and constant chants for sanctions against the hated and incorrigible Remington. It did
2 not take any special brilliance to discern what Gans had written initially in a motion document,
3 which Gans then proofread, edited and then routinely copied-in some of his pet tired inaccuracies
4 and cliches going back several years.
5 Without doing a detailed study of all of his motion documents, probably Plotz took almost 20
6 months to fully cross the line totally in his intentionally fraudulent and unethically inaccurate
7 opposition to Remingtons severance motion regarding the two proposed 2016 trials. Again, without
8 becoming unduly mired in irrelevant detail, Plotz frivolously miscited Remingtons consolidation
9 motion reasons from eight long years before and knowingly falsely claimed that nothing had
10 happened during those eight years to make 2008 consolidation reasons absolutely void, irrelevant
11 and absolutely incompetent eight years later after thousands of changes in the cases about 50 of
12 which were fundamental and extremely important! Therefore falsely claiming that nothing had
13 changed in eight years was simply dishonest, unethical and arguably grounds for disbarment in
14 itself, although here, when the next CCP 128.7 motion is served and filed, we have dozens of
15 similar unethical plus criminal acts not just one.
16 Plotz wrote many disingenuous, false, unethical and knowingly inaccurate declaration and
17 motion documents through May 2016, with MIL #20 probably reaching his deceitful, illustrious
18 climax. However it was his assistance to Gans beginning in July 2016 and his thereby becoming an
19 accessory, aider and abettor, probable occasional perpetrator and constant confidant to Gans
20 federal predicate witness tampering, obstruction of justice, suborning of perjury and the other
21 related and cited federal predicate crimes, which pushed Plotz over the line into becoming a
22 corrupt attorney. That is what he is now and Plotz is now going to have to prove his innocence
23 because his guilt is obvious and memorialized in at least 35 corrupt or fraudulent writings,
24 many of which have already been discussed herein and the rest will be considered in detail during
25 federal discovery and related criminal investigations.
26 Plotz is now normally the acting, and motion writing, Consigliore to and within Gans Mafia-
27 like enterprise family, and will now have to fully and competently defend his knowledge and
28 activities. We will shortly cover his knowledge and complicity in Gans and the Enterprises criminal
acts many of which Plotz had contemporary knowledge of, but was silent about. Without citing the
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1 scores of criminal vandalisms, evidence spoliation, tampering, concealment and obstruction
2 generally, and all of the other specific felonious acts by John Mathson listed above, suffice to
3 say here that Plotz has knowledge of all of that, both from Remington and from Gans at a
4 minimum.
5 Plotz is the ultimate insider and has been Gans right-hand man for years. Brisso keeps quiet
6 and may well be the overall Godfather here, but at the moment based on present facts, Brisso is just
7 another top-level criminal accessory on the inside of much of this, but likely could never know as
8 much as Gans and Plotz. Combining the Mitchell firm leadership discussed above with Mathson,
9 Olson and Skillings, there are plenty of days when the enterprise and their racketeering activities
10 would appear to be merged into one entity, four hours or days, but not permanently or immutably.
11 When Kluck and RAOs insurer become firmly enmeshed and permanently involved here during
12 2017, all power and Enterprise corrupt orders and actions may take on a different form, but we will
13 wait for discovery to evaluate that.
14 Because Olson and Skillings are powerful, mean, ruthless and well-established criminals, as
15 we get deeper into 2017 it appears likely that they and Kluck will abandon their hereto for
16 somewhat passive involvement in the enterprise and are very likely to fight Gans for top RICO
17 leadership and to take a harder line about how best to get rid of Remington. The present civil
18 criminal leadership which emphasizes corrupt trial advocacy, perjury, file room saboteurs and
19 having judges in your pocket (like the Godfather), etc could easily disintegrate into ruthless
20 REAL Mafia-like, Luca Brassi wanna-be, messy and violent tactics, where if Remington survives at
21 all he might have to go into a federal witness protection program if his above-described security
22 measures should fail.
23 8. Describe the alleged relationship between the activities of the enterprise and the
24 pattern of racketeering activity. Discuss how the racketeering activity differs from the
25 usual and daily activities of the enterprise, if at all. This is a rather complex and
26 philosophical question, but one which was covered in great detail above already. What follows
27 below is intended to expand somewhat on what we have already said.
28 A. First we need to understand what the usual and daily activities of the enterprise are.
To do so it is important to remember that:
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1 1. The enterprise is not an actual visible organize physical entity but is a loose
2 association of individuals whom Gans contacts by phone email or in person and issues orders and
3 they do various work activities for him usually in groups of about one the five;
4 2. The enterprise is usually not full-time, and is barely even permanent part-time, and
5 possibly could be characterized as temporary part-time but is operated that way for many years,
6 usually only a few hours in a day or even in some weeks. Although every week is completely
7 different, Gans RICO enterprise may only exist, or actually act occasionally, or for a few days out
8 of some months, such as the last six months prior to the filing of this complaint. Sometimes Said
9 RICO enterprise could potentially operate for no days in a month, and other times such as during
10 trials in pretrial hearings such as in 2016, it may operate continuously 30 days in a month, and for
11 eight (8) straight months as it did recently during 2016. Remington could graph the activities of the
12 enterprise at his deposition or during trials, and eventually may do just that, if it becomes relevant.
13 On the other hand, after the enterprise receives these complaints, by April 2017 the top guiding
14 RICO leadership which surrounds Gans in the Mitchell firm offices, will need to become fully-
15 activated and fully engaged again, FULL-TIME for presumably the next several continuous years;
16 3. Gans offices in the Mitchell firm exist there 24-7, However it probably acts as the
17 enterprises home office and operational nerve center only an average of 7-12 days per month. The
18 reason it is intermittent and part-time in the extreme is because the enterprise only relates to the
19 Remington litigation, which the Enterprises objectives and purposes are centered around. If the
20 Remington litigations are suspended, stayed or otherwise rendered inactive for a time, then there is
21 no enterprise at that moment. It still exists in the abstract, on paper and in Gans head, and it can
22 spring back into existenceIn seconds at any time from any Gans phone call to any member, but if
23 no one is issuing any orders and no one is operating on their own volition against Remington, then
24 effectively the enterprise is inactive on that day, and in effect does not even exist. On the other hand,
25 if Gans is ruminating, plotting and planning retaliatory actions in his mind and then billing
26 Lawrence for that time then the enterprise would be operational and in essence turned-on,
27 however if no time is billed and Gans and Mathson are just plotting and scheming for their own
28 enjoyment then arguably the enterprises dormant until such time as they bill Lawrence for their time
planning the next criminal extortive acts against Remington.
612
1 On the day that the Remington litigations all end and are resolved, potentially the enterprise
2 will cease to exist permanently on that day, unless Gans or some other errant, crazed soldier decides
3 to get in another few blows on their own volition against Remington or the Burl Trees interests,
4 just for the fun of it. However, realistically, Gans RICO enterprise is not likely to ever end until
5 he is in prison because otherwise he and his Mitchell co-conspirators will continue with deceitful
6 and corrupt new lawsuits, defenses and endless appeals until Remington either runs out of resolve
7 or dies;
8 4. Even on days that the enterprise is active, ordinarily they do a majority of ethical
9 and legal work, as repeatedly explained above. For example, during the recent 2016 trial with 5-6
10 RICO witnesses being feloniously coached to commit perjury, even then perhaps up to probably
11 55% of the enterprises activity on the day of a three-hour trial might be normal, non-criminal
12 litigation activity, with 20% very unethical and improper direct trial activity, with only 5% of the
13 total time of that trial day overtly and seriously criminal, however, the remaining 20% would also
14 be seriously criminal in the planning and coaching of the next days seriously criminal perjured
15 testimony, false exhibits and intentionally prejudicial and/or otherwise irrelevant photographs, etc.
16 In any case, however Remington or Gans makes the calculation, it is absolutely certain that
17 the component of serious prosecutable and imprisonable illegality is increasing exponentially in
18 2016. There are many ways to look at that anomaly, to address it here or to try and understand the
19 partial paradox of a psychopathic criminal only committing crimes for perhaps 25% of his work
20 day, while doing other ordinary and perhaps altruistic work for the rest of his day. As we explained
21 fully and adequately above, just because a criminal only spends 25% of his day killing, maiming
22 and destroying, etc. does not make him a saint no matter what ELSE he does for most of his day.
23 For example, if one witness is on the witness stand for one hour and answers mostly
24 immaterial questions absolutely truthfully 75% of the time, somewhat deceitfully, invasively and
25 not entirely accurately another 20% of the time, but then falsely swears to direct lies, which are
26 perjury on material case issues, only 5% of the time, that witnesses still a perjurer who may be
27 subject to imprisonment. For further example, even if only three (3) of said witnesses sworn
28 answers comprise actual perjury, then arguably that enterprise member and that enterprise activity
on that given day is only 5% potentially in violation of a federal predicate act, whereas the other
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1 95% is something different. Even that 5% perjury might not be a legitimate racketeering violation of
2 a federal law, without somewhat more such as extortion, bribery or provable witness tampering and
3 obstruction of justice, etc., so this can get quite complicated conceptually;
4 5. Furthermore, as analyzed further below, how much criminality is too much? No
5 criminal murderer, arsonist rapist or violent bully commits those actual acts more than perhaps 1%
6 of his time. Even counting the preparation and planning time, buying supplies, ammunition and
7 other weapons, over a years time the worst violent criminal who has committed five murders in a
8 year now waits on death row probably spent less than 1% of his year violating federal predicate
9 acts, assuming that murder is such, which is questionableAnd not automatic. For the purposes of
10 this document, Remington assumes that any serious proven criminality is too much, and does not
11 matter what else the criminal does with the remaining 99.9% of his time;
12 6. Gans RICO enterprise therefore operates at full throttle and with full intensity and
13 speed only very intermittently as a result. The above-described loose association of 30-40 people
14 only operates as this RICO enterprise when it involves the Remington problem or some aspect of
15 the Remington litigations, or somehow otherwise tangentially advances the numerous stated
16 detailed objectives and purposes of this particular RICO enterprise. Why that would be is quite
17 obvious, has been alluded to and at least inferred above and could be much further explained in a
18 deposition or other suitable forum, if anyone is really interested;
19 7. It therefore follows that the enterprise never meets or operates as an entire, unwieldy
20 and unnecessary unit of 30-40 people, but ordinarily functions as 5-10 or less, loosely organized
21 individuals, on a given day and at least 10-95% of that activity will be honest and not unlawful.
22 When, lets say eight (8) RICO people are functioning on a given day, it would ordinarily be
23 in preparation for trial a few days later or their performances and coordination during an actual trial
24 and then thereafter as they become coached and prompted for their next days ordinarily
25 disingenuous trial or deposition testimony, or perhaps where they take the time to read an at least
26 partially false and inaccurate declaration draft which Gans has prepared for their signature.
27 The above 10-95% of expected honest activity and trial preparation is a wide range, and
28 means that for example on a given three-hour trial day, that the enterprise is actually operational
and functioning, there might be only 5-10% of illegal extortive or perjurious acts during the three-
614
1 hour trial which over the entire day is a very low percent. However, it only takes one enterprise
2 member doing one federally illegal predicate act, or repeating it a couple times, to turn this whole
3 organized operation into a corrupt and criminal RICO enterprise. Examples of the above testimony
4 actually did occur from Gans perjurers in August 2016, when they typically spent 15 minutes on
5 background and only one minute on the material lie. However, during cross-examination
6 Remington focus to mostly on said lies and with repetition probably typically resulted in a typical
7 witness swearing knowingly falsely for perhaps only 35% of their time on the witness stand, or for
8 perhaps 30 minutes out of an entire day.
9 In a loose organization of this type, obviously every day is very different. On a day where the
10 enterprise commits one murder, one vandalism, one mugging and five extortions those crimes are
11 not eliminated by five more consecutive days of substantially honest if overzealous trial
12 preparations involving mostly legitimate photos, charts and other evidence, even if they are always
13 knowingly grossly improper, prejudicial, inflammatory and probably discardable upon appeal.
14 Neither would five (5) consecutive months of going straight for a while, eliminate one day
15 with several predicate acts, and exonerate Gans or eliminate any of the criminal acts alleged herein.
16 Here, Remington has alleged many serious predicate acts over the course of four (4) years,
17 sometimes on consecutive days, but ordinarily a month or more apart between the most serious acts
18 specifically complained of herein;
19 8. It does not take much criminality, or very many minutes spent conducting federal predicate
20 acts, to turn Gans clearly organized and optimally functioning diverse group of individuals
21 and associations into a prosecutable RICO enterprise. After all, any criminality is unlawful and
22 punishable. At least it used to be under the old morality and system of laws, however
23 unfortunately with the advent of fake news, distorted and/or alternative facts and no clear
24 concept of right, wrong, truth or honor coming from the top of the political (executive)
25 establishment, perhaps the rules of changed and Remington is now an obsolete ethical dinosaur.
26 Ironically, Remington wasted a lot of time attacking Gans ethics and morality for many years
27 without much result; however, now it appears that Gans was and maybe still is somewhat ahead of
28 his time in leading the abandonment of and renouncement of any conception of morality, justice or
doing the right thing (such as the polluter cleaning up the mess that he admits that he made), and
615
1 in fact Gans has made his own facts and practiced the extreme use of false logic and false experts
2 opinions since at least 2011, and hence he is in the of avant guard of deception, corruption and
3 creating false realities. Maybe Gans should go to Washington, and in any case, if convicted here
4 probably he will eventually be eligible for a presidential pardon for merely being convicted of
5 parlaying false facts, alternative truths and other versions of reality which might theoretically be
6 correct, had they not actually been proven false by standard scientific principles, logic and actual
7 incriminating admissions by defendants themselves.
8 Under the RICO act, only two predicate acts over a reasonable length of time are necessary
9 to prove the existence of an enterprise, and in this case Remington has alleged at least 40 predicate
10 acts or very close to that many, over a reasonably long period of time, which continuity and
11 longevity issues are discussed elsewhere. At least 40 predicate acts are explained herein, but
12 proving 2-3 is legally sufficient. Even if during the normal activities of Gans litigation activities
13 against Remington, only one percent (1%) of the time spent therein involves actually committing
14 vandalistic, extortive and other serious actionable criminal acts against Remington, that is a lot and
15 that is very serious, especially if you are the victim;
16 9. Gans enterprise carries-out very serious crimes, but for only a small fraction of the
17 workday. Further, as an example, even if Gans enterprises usual and daily activities consisted
18 of only one one thousandths (1/1000ths)of bona fide criminal activity over one year, that is still a
19 lot of very serious crime, whether the enterprises full-time or only very artinerantly part-time.
20 1/1000 of 365 days is approximately 6-8 hours. Many murders, extortions, arsons, perjuries and
21 related federal predicate acts can be done in only one hour. Multiply that by 6 to 8 and enough
22 violent, destructive or related serious predicate acts could be committed during that time by 20
23 people in only one year to lock them all up for life.
24 Similarly, at only a few minutes each, one Mathson, Skillings, Gans, Randall or a Kishpaugh
25 could do the same. Hundreds of serious federal crimes can be committed in just a tiny amount of
26 time, and thatIs often what has provably happened here. Remington has alleged that there are
27 several felonious perpetrator type criminal soldiers taking orders from Gans in this
28 enterprise, and they are the ones that do the destructive or violent acts in the field, however, the

616
1 majority of the federal predicate acts alleged here are of the different type as discussed next at 10.
2 below;
3 10. Arguably, the vast majority of the federal predicate acts committed by this
4 enterprise are of the white-collar, disingenuous legal-motion, mail-fraud type, which are
5 thoughtfully, and just as deceitfully and corruptly, done from Gans offices, as any violent
6 destruction which Mathson and Skillings do against Remingtons property.
7 In other words, at least 20-50% of all of the predicate acts alleged here involved Gans,
8 Brisso, Plotz, McBride and others operating from their desk chairs making threatening and extortive
9 phone calls, planning, plotting, drafting and discussing letters which are fraudulent in their purpose
10 and at their core, and then sending emails with the same identical deceitful content, or orally
11 coaching false testimony in trial witnesses, etc. Much of the above corrupt RICO activity against
12 Remington appears on the service to be ordinary aggressive and ruthless litigation activity, however
13 when carefully analyzed as herein, it can and will be proven that the small percentage of criminal
14 acts cited herein justify the conviction and imprisonment of the RICO leadership and all others who
15 now knowingly pursue Gans Enterprises illegitimate and illegal goals.
16 In other words, it is important to remember through all of this analysis, that defendants
17 litigation conducted under Gans leadership, still involves mostly ordinary legal or semi-legal non-
18 improper documents and activity, heavily interspersed with plenty of disreputable and unethical
19 statements and activity, but no felonious activity which clearly crosses the line leading to prison.
20 Gans is obviously no Boy Scout, never could be and always has been a ruthless, unethical,
21 grossly overzealous and emotionally involved advocate, however, he is not yet a crazy
22 psychopathic mental case, either. Basically, and continuously since 2006, he commits whatever
23 crimes he needs to try to win, and generally no more. One of the many important points to
24 remember here is that: Even if a person, such as Gans performs 1 million altruistic and wonderful
25 acts in succession over a two-year period, but then commits two extortions and only ONE brutal
26 murder, then he is not only very seriously guilty of conducting a RICO enterprise, under the facts
27 specified herein, but he would likely get the death penalty, personally, plus many of his other fellow
28 enterprise members would also certainly go down with him.

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1 Also, as alleged throughout, the worst extortions that actually made Remington and Figas
2 fearful, unable to properly sleep at night, and which partially accomplished their goals, many times,
3 were mostly just simple words, ostensibly innocent appearing, courtroom corridor, phone or
4 other conversations or mutterings, which appear superficially to be far different than murders.
5 Recordings of several of those events, would infer differently, to a judge and jury.
6 Fortunately the law recognizes that mere words can cause unbearable fear and pain, and
7 hence do severe damage, and federal extortion law makes it unlawful for Gans to make Remington
8 offers that he cannot refuse, or at least he would be most likely very stupid to refuse, and
9 Remington can therefore recover damages as a result.
10 11. The enterprise leadership arguably spends only an estimated 8% of their TOTAL
11 paid working time (over a year) engaged in blatantly, provable fraudulent activity,
12 HOWEVER see the 20-page insert at Y, BELOW for unethical, corrupt quasi-illegal, but
13 nevertheless legal motion activity by Gans, Plotz, Brisso and other RICO members, which
14 violates all of their attorney oaths, just moral conventions and polite civil procedures, even if
15 said immoral and on ethical procedures mostly do not YET directly mandate federal
16 imprisonment, on the present record.
17 There are 3-4 exceptions to the generalizations in the last sentence, which when
18 Gans denies them under oath during Discovery, they WILL upgrade to become additional
19 RICO predicate acts, and meanwhile they exemplify for the Court what Remington is actually
20 up-against here, and has been since 2007.
21 Another specific statistical example of the above principles: If Gans, Brisso, Plotz and other
22 members of his inner circle and top leadership spend 20-50%, and USE 25% here, of their work
23 days doing fraudulent writing, but where only 50% of each day is devoted to the Remington case
24 and the period only covers two (20-day) months of time, then it follows from the above
25 assumptions that said defendants spent a mere 20-days total in said above period, which period
26 could be as long as 6-12 months. 20 days above is only 160 hours. Assuming there are only 2000
27 working hours in a year, the mathematics of this example would therefore indicate that only 160
28 2000 hours or about 8% of their total time was spent doing RICO enterprise work improperly
directed at Remington, doing fraudulent writing in the above example.
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1 That example is believed to be at least somewhat accurate for this alleged RICO enterprise,
2 and means that Gans and Plotz, et al spend 92% of their days or total time over the year doing
3 unknown non-Remington RICO case related work for other clients, plus some honest research and
4 some honest dialogue and planning and even the honest portions of their motions and declarations
5 are written during that 92% of the time. Again however, the problem is that 8% of a persons or
6 groups time spent on illegal activity is an imprisonable offense, even under the guise of being a
7 lawyer in sheeps clothing, in effect. If only one percent, or only 1/100th of a percent of a persons
8 time in a year is spent planning and conducting criminal activity, that is enough, and millions of
9 people throughout history have been imprisoned or killed for less than that;
10 12. Therefore, to put it another way, the Enterprises racketeering activity is very
11 different statistically from the normal daily activities of the enterprise, and possibly
12 couldEven be construed as an aberration from the ordinary routine activities of a law firm with the
13 public coming and going most of the day. In other words, clearly Gans enterprise and the Mitchell
14 firm usually spend the gross minority of their time battling Remington through the power of the
15 enterprise and do many other kinds of things most of the time. That provided a convenient cover
16 and for many years worked as an alibi for the Mitchell firm, but those days are now OVER, and
17 their crimes are now going to be fully and publicly exposed.
18 Again, however that is no excuse or defense for Gans racketeering activity. Even a mass
19 murderer probably spends only 2-3% planning and executing murders and that would apply to
20 whether he did 20 or 100 in a year. In other words, some, a little bit, or quite a lot of
21 extortive racketeering activity in a given month or year, are ALL too much, and is obviously
22 enough to be implicated in, convicted of a RICO cause of action in a proper case, and then
23 reasonably and fairly punished according to federal law.
24 13. Most of the enterprise members spend very little time on the Remington cases in a
25 given year. If one looks at the daily activities of the component groups, individuals, small groups
26 and associations which form the enterprise, we come-up with an entirely different perspective,
27 because most of these groups and associations spend only a tiny fraction of their total working time
28 in a given year on the Remington matter, and it is really only Gans, Plotz and John and Joy
Mathson, that are truly obsessed with this case. That group spends essentially seven days per week
619
1 on destroying Remington and THEY devote much more time than everybody else put together in
2 conducting and managing the enterprises activities, although we now know that there are a few
3 others that are very interested enough to put them into some sort of a middle category. Arguably,
4 as we explained above, the enterprise is functioning at any time that Gans or John Mathson are
5 plotting something in their heads and probably that is the default state of the enterprise, operating
6 many hours a day in that respect, but with usually only 1-3 people actually plotting, scheming or
7 committing felonies against Remingtons property, on a given day. However, mere plotting and
8 scheming without actually billing their time and getting paid for it by Lawrence would not fully
9 qualify as RICO activity, with the latter requiring actual perpetrated predicate acts and usually
10 getting paid for same. John Mathson is an exception to the above rule because he is not paid an
11 hourly rate and conducts acts of destruction and violence against Remington routinely and for the
12 sadistic pleasure thereof. He just received $20,000 for his previous several years efforts against
13 Remington, which qualifies him as a paid WHORE of the enterprise just like the rest of them,
14 however he works more on piecework and not hourly like all the rest of them, and especially Gans.
15 Although, it is an abstract argument subject to debate and interpretation, Remington here argues
16 that mere plot since schemes and Gans head are not emblematic of ongoing RICO activity, but
17 require at a minimum actual perpetrating predicate acts, which are usually compensated for by
18 Gans through Lawrence. That usually, but does not necessarily occur, by the hour for provable and
19 billed blocks of time, however in the case of John Mathson and perhaps Joy Mathson, Kishpaugh,
20 Randall and some others of their local gang members, they may have another non-monetary
21 compensation system, such as being paid in alcohol or drugs for their exemplary service against
22 Remington, which has not yet been discovered.
23 In any case, we conclude at this point that about 93% of the enterprise members rarely do
24 any RICO business most of the time, except for approximately 2-3 months before trials and
25 summary judgment motions, during which time they may put-in 10-30 hours or thereabouts, mostly
26 on consecutive days, or close to it.
27 14. The enterprise is usually dormant, concealed, secret and looks innocently like, and may
28 even behave like a few conscientious attorneys, with secretaries, just pretending to be
conducting ordinary businesses. But then a Mafia family or Murder Inc. organization would
620
1 also have a similar, false and misleading facade, so you must know an organization by its
2 actions not by its pretty face.
3 In view of the above analysis, and the known and conclusive fact that none of the enterprise
4 members outside of the three mentioned above (plus possibly a couple others), spend even 5-10%
5 of their time in a given entire year doing enterprise work, it therefore follows that if one were to
6 study the daily appearance of the enterprise it would usually, for 90% of most days, look like an
7 ordinary and innocent collection of perfectly regular-looking businesses. That would be the default
8 state for the usual and daily activities of the enterprise. Kind of like an innocent-looking small
9 rattlesnake sunning-itself on a rock, when you have no knowledge of snakes or poison. However as
10 we have argued above, the enterprise doesnt actively exist at all much of the time, and except on
11 days or hours when one or more of its members are actively plotting, illicitly scheming and/or
12 actually performing criminal acts against Remington of some sort. Therefore, in between illicit
13 motions, trials, major discovery activities and because of other lapses in activity, Gans RICO
14 enterprise lies substantially dormant, as though it were asleep, however it can wake up instantly
15 from any tiny provocation and begin its deadly activity without any reminders or refresher courses
16 about what it was doing most recently, when it was last fully awake. In other words, the RICO
17 enterprise is always alive, even if dormant and will remain alive as explained above until Gans is
18 either in prison, or Remington and his several responsible and legally sophisticated heirs named
19 above, are also all dead.
20 That is quite different from saying the enterprise does not exist unless it is committing
21 racketeering activity, because although it does appear that way superficially, that would be wrong.
22 The enterprises litigation activity and attempts to fulfill their purposes and objectives still consists
23 of more than 50% of normal, legitimate or various stages of illegitimate and unethical behavior and
24 activity, but none of the above which are actual federal predicate acts in violation of the federal
25 statutes listed herein. As explained, it is the other perhaps 30-50% of the enterprises activities
26 which are not normal, legitimate or legal which must be carefully analyzed one by one to
27 determine if they are federal predicate acts are not.
28 Again, somewhat repetitively, Gans RICO racketeering enterprises actual provable,
seriously illegal activity is special, extreme, unusual, does not occur automatically every day, is
621
1 somewhat intermittent and occurs only a small percentage of the total time in an entire year (for all
2 enterprise members), however, seriously illegal activity does occur and it does not take many
3 predicate acts to a RICO enterprise make.
4 Also, of extreme relevance, are the above emphasized facts that Gans and John (and
5 JOY) Mathson in particular are plotting and also frequently actually committing brazen
6 criminal and destructive acts, against Remingtons property, for several hours per day
7 virtually every day. There are also at least 5-6 other enterprise members that also frequently
8 scheme, plan and plot illegal acts against Remington, they are just not full-time dedicated,
9 premeditated perpetrators of similar magnitude to the crazed zealots Gans and Mathson
10 Although they have a lot of help as explained, however, they are daily, serial criminal
11 perpetrators for at least several hundred days out of the year since 2012.
12 15. Does the RICO enterprise only do illegal work and criminal activity?
13 Again, this question which was originally responded to at least four months ago here has
14 been subsequently and repeatedly answered since then, including above. Simply put, the answer is
15 no; when the RICO enterprise is not doing illegal work in criminal activity it keeps itself occupied
16 in order to bring in needed money for its individual members to live by conducting ostensibly legal
17 appearing activities. Whether drugs are being sold, or other criminal activities are being
18 simultaneously conducted from the Mitchell firm offices, or not, has not yet been discovered, and
19 therefore Remington has no opinion whatsoever at this time about other possible criminal activity
20 being conducted from the enterprises main offices.
21 Finally, as per this portion of the most recent 2017 analysis:
22 1) Gans enterprise exists every day of the year but mostly does nothing and is inactive,
23 dormant or asleep typically, except for the various busy and semi-isolated periods every several
24 years, and sometimes much more frequently and for many months consecutively, around trial dates
25 especially;
26 2) On the days or hours that it does do work, the vast majority of it is ordinarily legal, or
27 probably as a Gans-involved default it is unethical legal or litigatory activity but is probably not
28 explicitly unlawful, and even then the average and typical Enterprises daily activity involves just a
very few people doing mostly, but not all, noncriminal work, which therefore by definition would
622
1 not violate federal law. However, as extensively explained above, it doesnt take very many minutes
2 a year to commit sufficient federal predicate acts to warrant imprisonment;
3 3) Remington presently estimates that during 2016, only 1-10% of Gans RICO enterprise
4 activity was seriously criminal in certain months, but not all months. Brevity precludes a detailed
5 analysis of which months were better or worse, which could be done, however the point is here that
6 any serious criminal activity involving two or more predicate acts is enough to allege and to
7 prove an extortive racketeering enterprise. In any case, Gans, Plotz, Brisso, McBride, Lawrence and
8 the other relevant RICO leadership here all know already which months had increased criminal
9 activity and why that was, and therefore they are already aware of the specific charges against
10 them without Remington providing another 20 pages of explanations. Finally, since Gans RICO
11 enterprise provably engaged in a substantial number of federal predicate acts, even if Gans group
12 only required a relatively few number of hours out of the entire year to commit those crimes, we
13 therefore have an obvious criminal enterprise and family here. Further, and in view of the
14 additional extensive analysis above, since all other numerous, complex and sophisticated RICO
15 definitional criteria are all met here, we therefore have an actionable RICO enterprise, under the
16 exacting definitions and specific criteria defined by the federal Supreme Court.
17 THEREFORE, as discussed throughout, since all RICO enterprise criteria are obviously met
18 here easily and then some, therefore logically we have a RICO enterprise here which must be first
19 acknowledged, understood, and accepted.
20 Thereafter, and NEXT, this court should facilitate and allow Remington and/or other
21 investigative authorities to fully expose the activities of Gans enterprise, initiate comprehensive
22 discovery and otherwise aid in and assist with the prosecution of it, directed towards the eventual
23 goal of conducting a suitable federal trial with the ultimate purpose of ending Gans enterprise and
24 punishing it.
25 B. What follows are various miscellaneous comments and further details, drafted in fall
26 2016, regarding the observed daily specific activities of Gans RICO enterprise and how said
27 activities may either equal, be equivalent to or mostly different from patterns of racketeering
28 activity, as defined by federal law. Although, admittedly somewhat repetitive, nevertheless there
is enough new probative material which follows here to leave it in here to familiarize all RICO
623
1 members with the exact allegations and criminal charges against them and the specific reasons
2 therefore.
3 Importantly, as explained above, most of the time the enterprise does not commit felonious
4 acts but often these very Mitchell firm RICO leaders depart from their Remington-focus to other
5 legal activities and are believed to handle a few other selected clients, to be further discovered.
6 Even Gans, Plotz and Brisso do some honest litigation and business activity, or assist others in that
7 regard, and therefore they straddle a wide line between ethical, unethical and illegitimate advocacy
8 for most of their working hours. As explained above, even if the named RICO leadership spends 80-
9 90% of their time performing legitimate and mostly legal tasks for other clients, that still leaves a
10 huge amount of time over the last four years for their primary and prominent RICO racketeering
11 activities. In that regard, in this November 2016 estimate we calculated that the above leadership
12 spent at least an estimated 11% of their overall time and working effort, on the various types of
13 corrupt and illegal violations listed in all of the 16 or more specific categories of the mostly various
14 18 USC federal law violations, which are alleged throughout these documents.
15 1. The above term overall time and working effort means that the enterprise is only
16 functioning as an illegal advocacy and corrupt organization when one or more of its members are
17 being paid for their work, which as we demonstrated might be weekly, or only every 5-8 years as
18 with John Mathsons recent $20,000 payment. Most days only Gans, Plotz, McBride and probably
19 Brisso are being paid hourly and on a majority of the total days of a year probably no more than an
20 additional 3-4 enterprise members are actually working at a given hour in a given day. John
21 Mathson is an enigma himself and although he ostensibly is not normally paid hourly for his efforts,
22 receiving $20,000 for his long time criminal destruction and vandalism efforts probably breaks
23 down to possibly $2-5 per hour, more or less, if an actual hourly calculation were to be made of his
24 many thousands of hours spent circling, planning, harassing, lying in wait to photograph, extorting
25 Remington, ETC., all with the sole focus of coercing, intimidating and damaging Remington
26 personally, in every way he can conceive of, plus destroying as much of his Burl Tree property as
27 possible, and until that become so intolerable that he has to move.
28 2. Legal activity? As explained above, when Or whether the enterprise is conducting
legal, semi-legal or plainly unlawful activities requires a subjective judgment, which would be
624
1 different almost every day. That means that ordinarily that if 1-5 RICO members were working for
2 a few hours on a given day, Gans and Plotz might be primarily plotting and planning for illegal
3 activities or unethical which were not prosecutable as crimes. Whereas, the other few members that
4 were working that given day might have been writing-up their actual honest reports for an entire
5 day but then when they submitted them to Gans for his revisions and additions the next day, and
6 subsequently they read and signed-off on the new false and corrupt portions of their expert report
7 (lets say) written for them by Gans, then perhaps one half hour on that following day would be
8 corrupt enterprise racketeering activity intended to further their objectives against Remington. In
9 other words, none of the racketeering activity here is especially clear, simple or straightforward,
10 however overall it is very intuitive and obvious if one understands how an organized corporate or
11 business group divides up and delegates its labor to reach an important objective.
12 The enterprise does, or performs, lots of legal activity as it operates in the conventional
13 environmental engineering world, and for example when Gans approaches the Humboldt County
14 Division of Environmental Health, the majority of the interaction and communication is probably
15 honest, factual and legal, but at some point a corrupt twist is added either in Martel or Esko's offices
16 and definitely FROM Brisso, at the Mitchell firm, and then the former just sign-off on it,
17 inferentially anything Brisso requests is granted. A recent example of that would be how the
18 Mitchell firm, Martels office, Judge Reinholtsen and the county counsels office, in some sort of
19 improper conspiracy, to be further discovered, have set-up very difficult hoops and
20 requirements for them to let Ms. Hoyos testify, and perhaps have already made it impossible for
21 her to testify at all, at the next contamination trial. Presently, the combination of those
22 aforementioned factors have inexplicably prevented her from testifying at all, which would be
23 grossly unfair and unjust.
24 Again, most of the enterprises activities are a subjective mixture of the three types of activities
25 listed above: legal, semi-legal (probably unethical and improper), or unlawful criminal conduct. If
26 the above-referenced enterprise members are conducting illegal activity and committing crimes of
27 some other sort, but which do not involve the Remington case, such as getting a speeding ticket
28 perhaps on the way to Gans office, then that would obviously not be a relevant RICO enterprise
predicate act here. Again as is rather obvious this RICO enterprise alleged herein only relates to the
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1 enterprises objectives directed specifically against Remington, while Remington assumes that
2 Gans does other illegal activity, that has not yet been proven and is not implicated directly in this
3 RICO case, however it would undoubtably be of interest to investigating authorities, sooner rather
4 than later, and also to a jury.
5 Based on present information, it is apparent that probably only John Mathson, Kishpaugh,
6 Plotz, Gans, Skillings and probably Lawrence, at times devote a substantial amount of their life,
7 energy and career towards this RICO enterprises objectives and to crushing Remington completely
8 here. And in that regard, it is unquestionable that only John Mathson and Gans devote the
9 majority of their working day, life and career to a processing about Remington and making sure that
10 this RICO enterprise works and succeeds, BUT even they take weeks or even months substantially
11 off at known, documented times over the last nine years. That would be perhaps analogous to the
12 godfather and his Consigliore Tom Hagan who together spend substantial, or at least sufficient, time
13 every day plotting the daily and weekly course for the Mafia family, but only issuing actual
14 criminal orders every few days or so. The rest of the time, the loose association of individuals and
15 organizations conduct other work, inferentially largely lawful, independent of the enterprise and
16 essentially just wait by the phone, or wait for emails which provide new schedules, new work
17 activities to consider and actual orders to execute, from the Enterprises top leadership gang.
18 Again, as explained and hypothesized above, the vast majority of the enterprise members, for
19 example, Brisso, Martel, Randall or even possibly Judge Reinholtsen spend very little time
20 following Gans corrupt orders or involved with this RICO enterprise, at all. What that means is that
21 probably that above group spends no more than 1/1000th of their annual work effort assisting Gans
22 to defeat Remington, except around trials and serious trial preparations.
23 However, as proven above, 1/1000th of the working time in one year or 4-6 years adds up to a
24 lot; and, again as alleged and discussed above, the time to commit a murder, take a bribe or commit
25 an extortion is only a few minutes out of the year and may be less than 1/10,000th of an enterprise
26 members year, but the fact that a criminal act was done quickly does not make it any less illegal, or
27 less punishable under federal law.
28 3. Which RICO members are the most guilty? At the proper time, especially after a trial
and where sentences or punishments are to be reasonably determined and prescribed, Remington
626
1 will have an additional large quantity of gathered relevant facts relating to each named or guilty
2 enterprise member to provide as advice to any trier of fact here.
3 All 30-40 enterprise members and associates have been involved in corrupt activity but
4 obviously some of those illegal acts or unethical, corrupt, but borderline federal law violations are
5 worse in others and in fact in severity could be rated from about 5 to 100 probably. There is no
6 doubt, that based on what Remington knows today, some of these enterprise members are 20 times
7 more guilty than the least culpable person named here, and when it comes to Gans, he would be 85-
8 100 times more guilty than any other person named here, not named John Mathson or possibly
9 Skillings or Lawrence, as will be discovered. As referenced above, probably Plotz is presently in
10 the most ambiguous and enigmatic position and whether his culpability is 5-10 times average, 1/3
11 of Mathsons an/or 1/10 or as much as 1/5 of Gans guilt and degree of punishment, and which
12 guilt increased drastically every month during 2016, is presently not fully determined. What he
13 does next and how he responds to written discovery and the imminent civil and other investigations
14 in 2017 could affect his eventual situation by 500-1000%. Obviously, if he pleads insanity (and
15 in essence accuses Remington of that), denies all and backs-up Gans 100% on everything, then
16 he would quickly advance himself into becoming an accessory, primary aider and abettor and
17 occasional perpetrator. If the latter occurs, Plotz will rapidly become potentially just as guilty as
18 Gans himself, and subject to major prison terms, in Remingtons opinion. Joy Mathson is in a
19 similar ambiguous position who arguably is just as guilty as John Mathson or Gans, and therefore
20 her discovery responses going forward in the federal case will be crucial to her. Defendants have
21 been willing to win at any cost and irrespective of any minor ethical or truth issues, and now they
22 will need to determine if crushing and defeating the hated Remington is worth risking a few years
23 of prison, and whether they really have faith that the clever but often blundering Gans can keep
24 them out of it.
25 4. Gans conducts a part-time RICO enterprise against Remington. As discussed above, the
26 entire enterprise membership outside of the top leadership is strictly part-time and 85% of their
27 members are extremely part-time. Also as inferred, even Gans, Plotz and John Mathson do not
28 devote 100% of their time in a year to this RICO enterprise and destroying Remington and his cases.
Some weeks and months they do, but there are always lulls, and Remington really has no idea what
627
1 they do when the cases are suspended for several months at a time. What we do know is that
2 Mathson and parts of his local gang, constantly keep-up the destructive pressure on Remingtons
3 property and gardens, almost daily, and all year long every year, as detailed above.
4 5. In other words, Remington herein alleges a part-time criminal racketeering
5 organization which has numerous effective and legitimate covers, such as an ordinary-
6 looking law office, some ordinary garden-variety legal activity, a few legal associates that may not
7 even be aware of the enterprise, and generally a motley and unorganized association of many
8 ordinary appearing individuals and small businesses. But, all of that is similar to a mafia family
9 operating a large legitimate retail grocery store which grosses $50,000 per day of ordinary food and
10 associated items, but they also significantly spend 10% of their time selling narcotics for twice that
11 amount of money out of the back room, which is analogous to what is alleged herein. Said analogous
12 grocery store which only spends 10% of its time violating federal predicate acts can still be a RICO
13 enterprise, if all of the complex other criteria are met, potentially as bad as any mafia crime family.
14 Also as alleged herein, even The Godfathers family did not engage 100% of its time and effort in
15 criminal activity, but much less. While the murders, arsons, violence and extortions get most of the
16 attention and publicity the other 90-98% of its time and energy would typically be spent on normal
17 business activities. One might argue that some of the other activities were in support of or
18 preparation for criminal activities, however going to the food store or getting new tires for your car
19 although possibly very indirectly related to criminal activity, at some point would be considered too
20 remote to be such and Remington here argues that in fact supporting activities for a criminal
21 operation may or may not be predicate acts depending on the individual fact of the case. Specific
22 logistical acts in support of Hitlers army would be in one category, and Plotz going out to bring in
23 some McDonalds hamburgers for Gans lunch would be in another category. In other words, the
24 enterprise exists almost continuously, but usually in a dormant state, and becomes a bona fide RICO
25 criminal enterprise only when it is committing seriously unethical or criminal acts against
26 Remington in order to further its objectives, such as within 1-2 months of a trial date.
27 During trials, and in trial preparations for months ahead of trials is when the RICO enterprise
28 operates continuously and when it is a serious menace to Remington and society. However, over the
many months and years, usually the enterprise is in a latent, ready state to be plugged-in so to
628
1 speak, like an appliance such as a toaster, and Gans would be the only source of suitable electricity
2 to bring the enterprise into full functionality. Said toaster is always ready to be plugged in but
3 most of the time is not needed. For example, Remingtons toaster only works about 1/17,000th of a
4 day. Whereas, Gans enterprise would always work at least 1/100th of a day, and as above many
5 times would work essentially 24-7 for limited periods.
6 Most of the time the enterprise members are not acting as such and therefore whether the
7 enterprise exists continuously, for example while it is sleeping, and/or dormant and ready to
8 spring into action at any phone call by Gans, is a matter for philosophical debate, as attempted
9 above and herein, and can continue elsewhere in the future.
10 9. Describe what benefits, if any, the alleged enterprise receives from the alleged
11 pattern of racketeering activities.
12 That is a great question and is rather difficult to fully answer at this stage of the litigations.
13 Perhaps Gans should be the one to answer that one. However, preliminarily, all of the RICO
14 members are getting highly paid which keeps them excited and interested, plus the extortive
15 racketeering activities continue to give them hope that each day or week will be Remingtons last
16 and they will win all of this quickly. On the other hand, many of these racketeering activities just
17 kind of evolved naturally, just happened, and Gans assumed he would just get away with him
18 like he always does, so arguably many of them were not done consciously with the expectation of
19 a cause-and-effect result. Therefore, every month and year the above question would be answered
20 very differently.
21 Other than some short-term personal satisfaction by Gans, BOTH Mathsons, Skillings,
22 Kishpaugh and a few others, from their correct belief that they are hurting Remington and will
23 eventually prevail in the lawsuits, it is difficult overall to see how Gans alleged RICO enterprise
24 has yet received any REAL tangible benefits. Probably John Mathson is pretty happy now about
25 all this because he gets sadistic enjoyment from tormenting Remington and damaging his property
26 every day or two and recently got $20,000 for his efforts, so for him CRIME PAYS!
27 A. Gans and the Mathsons of course have a different way of measuring benefits and
28 they now apparently believe that they received enormous benefits from winning the 2016 SOL trial
by violating numerous federal predicate acts as alleged, both prior to and during the trial.
629
1 Remington does not see it that way at all, but will probably have to be vindicated either here or in
2 state appellate court.
3 Said defendants were very pleased and actually exhilarated when a juryWas totally deceived
4 and duped into determining falsely and incorrectly that Remington had seen defendants massive
5 contamination in 1998, and therefore should have done something about it immediately, even though
6 it was buried, 99% invisible and even though according to their false testimony there were no
7 hazardous or contaminated materials exposed which would have aroused Remingtons curiosity,
8 even if he had been there, which he wasnt. Therefore the whole decision an issue is quite absurd,
9 however Remington has to keep going over it because its not yet dead. Five convincing liars against
10 one older truth teller, could deceive a lot of juries, probably most of them.
11 Gans, defendants and apparently even Judge Reinholtsen believed the August 2016 statute of
12 limitations ruling was conclusive, and would end all of Remingtons continuing nuisance and
13 trespass lawsuits, which simply is not the case. At least one more state trial would be needed there, to
14 determine that because it is a jury issue, but then an appeal would follow more than likely unless this
15 federal case breaks through as anticipated, preempts the state cases and results in various stays of
16 the two state cases, which likely would never be determined for another 5-10 years.
17 However, if Remington is wrong in his above analysis and Gans, Mathson and the barely
18 involved RAO DOE defendants want to prevail with finality in all state cases, then it would be a
19 certainty that the RICO enterprise had won a great victory! That would have accomplished one of
20 their major goals, purposes and primary objectives which might very well inevitably lead to all of
21 their objectives being accomplished, including the financial ruin and ultimate crushing of Remington
22 and his businesses. That is about all they seek and the federal predicate acts committed in August
23 2016 and earlier, put them well on the road to accomplishing their objectives, and if so those would
24 be great benefits to the enterprise. In other words, it took nothing less than an all-out state and
25 federally criminal RICO enterprise effort for Gans to win his limited 2016 SOL trial verdict, which
26 has at this point knocked-out Remingtons valid discovery rule exception. That victory would be
27 an obvious benefit to Gans RICO enterprise, in which was the reason that he formed it, therefore
28 at this time Gans is very excited at the results and benefits he has achieved by going slightly bad
and criminal. However, as explained, Remington does not need any discovery rule to sue in
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1 successive actions for continuing nuisance and trespass, but the state trial court may not have
2 grasped that philosophy yet, which is one of the reasons Remington is now here.
3 B. Otherwise, the continuous extorting of Remington and his experts, and defendants illegal
4 acts of committing the numerous above- described mail and wire frauds, and related money
5 laundering, bribery, arson and the many other numerous related criminal acts enumerated above,
6 clearly makes life difficult and unpleasant for Remington, and that alone is another great benefit for
7 the RICO enterprise. Any additional pain, discomfort and financial hardship perpetrated upon
8 Remington, therefore ostensibly brings defendants closer to their ultimate goals (at least in their
9 minds), but does not really produce the tangible financial benefits, and final ultimate victory that
10 their SOL trial victory potentially accomplished, at least in their minds.
11 Therefore, incrementally, every destructive act against Remingtons property by John Mathson
12 and Skillings potentially bring them closer to the RICO enterprises clear goal of saving hundreds of
13 thousands of dollars, and then possibly further suing Remington for that order of magnitude of
14 money for slander, libel, punitive damages and malicious prosecution, etc. At least, defendants
15 motion documents proves that they think so. Therefore, since August 2016, defendants, and all of
16 them are probably very gratified, exhilarated and optimistic about soon accomplishing all of their
17 enterprises objectives. Probably Lawrence especially is very excited that this will soon be over.
18 How she can justify the vast expenditures she has wasted trying to destroy Remington, and who
19 above her has approved her bad choices and irrational and overly-emotional decisions to blindly
20 follow Gans, Brisso, Plotz, et al, to hell and back, and effectively FOREVER, still remains to be
21 discovered. Defendants now assume that they will eventually save at least $1 million by the
22 combination of factors discussed above, but that hope has been glimmering for 6-8 years now. Just
23 starting this case, let alone losing it, or losing Remingtons eventual rather easy appeal in state court
24 of continuing and successive action cases DR 080678 and/or DR140426, would put them back to
25 the start. However, in reality they have been losing ground every year by committing themselves
26 to a provably false sworn record, as regards almost every significant scientific case issue, which will
27 all be proven at the next contamination trial.
28 However, Remington disagrees with all of the above described RICO plans, hopes and
assumptions of immediate victory, and this federal contamination suit and two RICO causes of
631
1 action are Remingtons response to the extreme and outrageous corruption and unlawful perjurious
2 verdict rendered in August 2016. Therefore, the enterprise has received great benefits in their
3 minds and perhaps objectively as of this date, however Remington sees that merely as a murderer
4 who was acquitted initially, or even merely released on his own recognizance pending trial, but then
5 was tried, or re-tried and convicted, or more directly analogous to this case, his initial acquittal
6 was overturned on appeal for a new and fair trial, which if based on the truth will absolutely convict
7 him. Knowing that he will absolutely lose in a fair and truthful trial, if that will be possible here (or
8 THERE) still, as Gans absolutely knows here in this case, then said murderer would be stupid not to
9 make some sort of a plea bargain or settlement, which appears to be inevitable here, if we can ever
10 get the criminal corruption out of this process. Here, Gans is the murderer and has been initially
11 acquitted for the most part, and the rest of the above analogies are yet to occur.
12 If Remington is allowed to proceed here in all causes of action, eventually, justice will have
13 to be done, barring Remingtons unfortunate and premature demise, because all facts and
14 apparently all California law favors that justice be done here to Remington, and that his property
15 be cleaned-up by defendants. As explained above, even if Bruce Remington does not receive
16 justice which he is entitled to, eventually the polluter will have to clean up his mess at least
17 Remingtons heirs and grandchildren should eventually have a pristine estate here again.
18 C. Additionally, and other than and aside from the above, and defendants corrupt, minor or
19 potentially completely insignificant 2016 trial victory, based entirely and completely on the
20 material perjury of John Mathson and the supporting perjury from three others fellow gang
21 members, plus his wife who was held in reserve, defendants RICO enterprise generally has
22 received few if any benefits from their criminal activity. In fact, Remington believes their
23 criminality causes more detriment than benefit.
24 Defendants probably discount and would laugh at the next point today, however every
25 criminal act of vandalism, theft and property destruction by John Madison, Skillings or Gans
26 merely increases Remingtons resolve overall because he is quite stubborn and hardheaded. But
27 for the almost daily torture and harassment, and the anger and energy that arouses in Remington, all
28 of this couldve been ended long ago, and certainly would have been had Aveggio lived. His death
did set all settlement or amicable resolution attempts back by 5-10 years.
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1 Meanwhile, Remington refuses to be bullied, intimidated and extorted by petty criminal acts
2 by bad actors and third class criminals such as those named above, even if so meticulously well-
3 organized under Gans brilliantly and demonically-planned enterprises leadership, backed by
4 unlimited financing. All of the RICO actors here are small-minded and petty criminals which could
5 not last in their frivolous and unjust war of attrition against Remington for many months, but for
6 Lawrences unlimited financing of any and all criminal schemes, devices and crimes which
7 Gans can invent. Rather like the enigmatic, conniving and probably crooked Donald Trump of
8 fall 2016 (who Remington reluctantly voted for then, but now believes should and will be
9 impeached at least during 2018, if not long before), Remington likes to strike back harder when he
10 is hit, especially when he is hit unfairly and unlawfully by Gans protection racketeering gang.
11 Remington is and has been a well-established and very successful leader, manager and businessman
12 for almost 70 years now, beginning as a significant and wealthy kid entrepreneur at age 8. He was
13 not bullied and intimidated then, or now. However, battling the unlimited power, weaponry and
14 finances of The Evil Empire, or the unlimited gold and financial resources of Sauron, or Nazi
15 Germany is difficult, and over a long enough time period the vast financial resources and what they
16 can purchase will inevitably triumph, maybe. It would be unusual, but not impossible for a court
17 to decide a case in favor of the underdog and under financed pro se litigant, and find that justice and
18 equity demanded just such a verdict.
19 However, as explained above, the August 2016 verdict was not helpful the Remington and so
20 far appears to be a substantial benefit to this RICO enterprise. On the other hand, if and when
21 Remingtons view of and plans for these cases prevail, then the August 2016 trial defeat will become
22 almost meaningless in terms of Remingtons damages, which were never requested for more than
23 three years at a time in any of these cases. Today, the state trial Motion in Limine (MIL) #20 is the
24 salient and dramatic prejudicial and erroneous ruling which is crippling Remington going forward,
25 whereas a false and wrong statute of limitations ruling is quite unimportant under Remingtons
26 image, VISION and perspectives on the cases. However in either event, and is fully discussed above,
27 Judge Reinholtsens ambivalent position supervising the state cases is detrimental to Remington
28 injustice and presumably will have to be dealt with in the appellate court, if or when he ever rules on
the February 17, 2017 issues, related to whats next for DR 080678.
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1 Remington is presently going-on as far as possible, under the present rulings and state court,
2 with the necessary second contamination trial, which next trial will determine whether remediation
3 is reasonable here, and whether Remington has alleged successive damages properly, etc. However,
4 all of that should be over soon enough and we can get back to the dozens of appealable issues that
5 have arisen just in DR 080678 alone in 2016.
6 D. Gans short-term 2016 Faustian bargain with the devil. Another way to look at all this
7 is that Gans and defendants appeared to win a short-term limited victory in August 2016, however
8 by doing so they inalterably crossed-the-line with multiple suborned perjury and numerous other
9 scientific, moral and factual inconsistencies, many other state and federal crimes, which they will
10 never be able to fully justify and put back in the box, so to speak. In other words, Gans sold his
11 own soul to the devil, and most of the associated RICO membership well now have to follow him
12 there, TO HELL, as they now desperately try to hedge and modify their state perjury into
13 something less than that in the federal forum, in order to reduce their likelihood of imprisonment.
14 That corrupt Gans RICO activity, especially throughout all of 2016, succeeded in angering and
15 motivating Remington, greatly increasing his resolve here, and provided the final straw to realize
16 that Gans had launched a major war against him using absolutely corrupt, ruthless, brutal war-
17 criminal and quasi-genocidal methods, analogous to chemical weapons on the battlefield, against
18 Remington, as opposed to Gans earlier and previously mostly ordinary ethical California
19 advocacy practices.
20 Does the enterprise benefit from extending these litigations out for nine years and then
21 another 6-9 yearsAfter that? The basic answer of that would probably be YES. Thats also a
22 complex and subjective question because the truth is that about 99% of the enterprise
23 continuously makes money here and does benefit GREATLY from all this lasting as long as
24 possible. That especially applies to Gans, Brisso, Plotz, McBride, et al who are all getting rich on
25 this and will eventually be able to retire with full benefits on this case alone if it continues along
26 these lines. What motivation do they have to end or resolve any of this?
27 Only Lawrence and Allied Insurance and presumably RAOs and maybe Nelsons insurer are
28 going to want to end this debacle sooner, rather than NEVER. Therefore, but for a couple of
insignificant and obnoxious insurers, that none of the enterprise members obviously really gives
634
1 a damn about, the enterprise itself and the vast majority of its members, especially its Mitchell
2 firm leadership, and very especially Gans and Plotz, the enterprise is benefiting and obviously
3 continues to benefit from violating federal predicate acts, which cumulatively have the effect of
4 prolonging these lawsuits indefinitely.
5 Therefore, like a lot of these interesting philosophical questions, this one is somewhat
6 indeterminate and cannot really be accurately answered today. Eventually, like a Mafia family, this
7 enterprise hopes to make more money from their illegal acts by eventually unconditionally
8 defeating Remington and taking his property and his money. However, that has not yet occurred
9 and if this RICO case succeeds as Remington would hope and expect then obviously all of the
10 pattern of racketeering activities will backfire and cost Gans and his men big time.
11 Around the time of the FAC in this federal case, and after substantial additional discovery,
12 Remington will probably update, amend, edit, condense and generally improve the clarity,
13 relevance and important detail of this RICO Statement, because today this question and some of
14 the others cannot be definitively or finally answered correctly. What is true today may well be
15 different, or even obsolete in several months.
16 10. Describe the effect of the activities of the enterprise on interstate or foreign
17 Commerce. In one word, they have been devastating.
18 A. Gans RICO enterprise substantially damaged Remingtons exclusively interstate
19 commerce business. As thoroughly explained in detail above and below, Gans racketeering
20 enterprise very deleteriously affected Remington and the Burl Tree business. Under RICO, its
21 impact on Remington personally is unimportant in itself and the state cases deal with those
22 numerous types of personal damages, from emotional, LEL and punitive to inadequate attempts to
23 compensate Remington for his permanent physically very seriously debilitating injuries, etc.
24 The Burl Tree has been in existence for approximately 45 years. It has had access to and
25 actually owned tens of millions of dollars of redwood burly stumps, suitable for making hundreds
26 of thousands of good redwood burl tables and other products. It has been very successful during
27 that period, grossing as much as about $500,000 in a year, always with a substantial net profit. It
28 has been as large as six (6) retail stores at a time, from Myers Flat to Crescent City, and often has

635
1 had two scientifically advanced redwood burl stump sawmills at a time, with approximately 30-40
2 employees at its peak.
3 For the last 30 years, the Burl Tree has predominantly operated in interstate commerce and
4 for the last 18 years it has operated exclusively in interstate commerce, with no local or
5 California retail sales presence.
6 Therefore the above conclusion is obvious and irrefutable. Gans enterprise has nearly
7 completely destroyed the Burl Tree which was an interstate commerce business, so literally
8 thousands of interested interstate commerce customers can no longer get any products from the
9 Burl Tree, with the one major exception being the US Justice Department in Washington, DC.
10 B. The Burl Tree. Significantly, today and since 1998, the Burl Tree has had zero
11 employees except for Bruce Remington. The Burl Tree for the last 18-20 years has been Bruce
12 Remington, no more and no less. Remington used to do the work of several men, and still
13 functions adequately, especially as a burl finisher, but now he only does the work of about one
14 third of the Remington of only a few years ago, due to his dump-attributed physical disabilities,
15 discussed above. In early 2017, for example Remington is now shipping $1200 worth of finished
16 plaques to the US Justice Department in Washington DC, with another $3000 plus in progress, to
17 follow shortly, at least until
18 spring 2017 when budget cuts seem to be affecting Remingtons Justice Department contracts.
19 The Burl Tree today still owns owns more than a half a million dollars worth at wholesale, of
20 unfinished redwood and some other species of burl and also has a variety of other projects,
21 products and other actually cashable-in ventures, now on hold47. Those include various
22 applications of large-format panoramic landscape photography, novel Redwood burl lampshades,
23 palatial redwood burl doors, and numerous other patented products and/or patentable products is
24 developed several years ago, including illuminated inflated balls and cable skydiving.
25 47
The Burl Tree and Remington have many undeveloped patents, products and hundreds of tons of unused inventory
languishing and deteriorating in value and timeliness, because Remingtons time is 100% occupied for years at a time
26 with battling Gans litigation-focus to racketeering enterprise which is sworn to win and crush Remington financially
and emotionally in the process.
27 All of Remingtons dozens of novel patentable products, patents, patents pending and related innovative
commercial ideas have been substantially on hold for about eight years overall, due to lack of time spent defending
28 Gans frivolous defensive motions. Those products include amusement park rides, illuminated game balls, cable-
skydiving improvements over the popular zip lines, burl doors, unique trade secret artistic panoramic nature
photographs and many other products of international and interstate commerce potential and sales.
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1 Rule eight (8) mitigates against writing another 40-pages here about the Burl Tree, but we
2 could, and at trial we will explain further how the Burl Tree has made its millions of dollars since
3 1970, and how its $100,000 per year of net income over the last 25 or so years dropped to under
4 about $4000 per year since 2006. The discovery of defendants pollution in 2006 marked the
5 beginning of the financial demise of the Burl Tree. As explained elsewhere, that demise began
6 with defendants elaborate cover-up of their contamination crimes, which first began rather
7 benignly in 2006-7, then became conventional litigation for the next 5-6 years, but since then
8 became seriously criminal by approximately January 2013, which continues exponentially in
9 increasing unlawfulness, in late 2016. That present increased lawlessness has been caused directly
10 by Gans and his RICO enterprise soldiers and numerous associates, especially John Mathson and
11 his local, well-described Westgate gang.
12 C. Gans extortion racketeering schemes and property destruction have nearly
13 destroyed the Burl Tree business. The illicit offensive and defensive litigation activity
14 perpetrated upon Remington and the Burl Tree by Gans criminal racketeering enterprise has had a
15 profound deleterious effect on the Burl Trees sales and profitability and therefore by definitions
16 on its interstate commerce purchases and sales. In one word Gans has had a huge and entirely
17 NEGATIVE influence on the Burl Trees productivity, creativity and sales.
18 How negative? Overall, at least hundreds of thousands of dollars per year, but potentially
19 hundreds of millions of dollars may have been lost which could be reasonably calculated by a jury
20 upon hearing about some of Remingtons excellent money-making ideas which are useful to the
21 world and not yet being duplicated by others, see some of them enumerated in footnote 47 above.
22 Additionally, Remington has enough dry burls in his present inventory to make approximately $2
23 million of finished burl tables.
24 Because all of Remingtons Burl Tree sales are now interstate or potentially international, all
25 of the ideas and unfinished and unsold burlwood inventory that is languishing and rotting around
26 the Burl Trees land here, is potentially lost interstate commerce and hence Gans enterprise has
27 reduced the Burl Trees normal share of fruitful interstate commerce by approximately the amount
28 of the damages caused by said enterprise, although the actual calculation is not quite that simple.

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1 11. If the complaint alleges a violation of 18 USC 1962 (a), provide the
2 following information: (a) state who received the income derived from the pattern of
3 racketeering activity or through the collection of an unlawful debt, and (b) describe the use or
4 investment of such income. Although 1962 (a) is not currently complained under in this
5 complaint, Remington does anticipate that violations of it will be alleged in the FAC before trial,
6 after substantial discovery is completed, and hence makes the following relevant comments below.
7 In other words, Remington does not yet possess sufficient facts in this RICO complaint from
8 2016- 2017 to presently allege an obvious violation of 18 USC 1962 (a) which actually, provably
9 and substantially damaged Remington or the Burl Tree, however Remington has information
10 which proves that defendants did make such illegal investments, but specific evidentiary details and
11 actual direct damages, sufficient to use at trial directly related to those investments are presently
12 unknown and whether Remington was injured significantly, provably and directly thereby, has also
13 not yet been established.
14 Most of Remingtons and the Burl Trees injuries were incurred as a direct aftermath of the
15 continuing anomalies and detriment flowing from defendants 1998-2000 corrupt dumping and
16 concealment activities originating on Mathsons land. In real time in 1998, Mathson, RAO and
17 others involved in the enterprise today made huge profits then, reinvested them primarily in real
18 estate, better owned and rented construction machinery and equipment, offices, fancy pickup trucks,
19 computers and daily living at a higher standard than they could have provided from legal
20 employment, took frequent trips and reaped many related exotic benefits of their unearned windfalls
21 of ill-gotten wealth.
22 Those facts above are known, but what direct impact or damage they had on the Burl Tree
23 property is a little less obvious at present, however improvements in all of RAOs above
24 construction and excavation equipment, standard of living, comfort, better transportation and
25 having unlimited funds to repair and maintain their huge loader, trucks and other rented or owned
26 equipment, ALL led to a larger and more damaging project to Remington and the environment. It
27 also allowed all of the defendants to live-well, prosper and confidently began and then continue
28 their battles to destroy Remington, using thir almost unlimited funds provided by the illicit hauling
and dumping of asbestos and gas station remediated soils at Mathsons illegal class I hazardous
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1 waste landfill. In other words, defendants immediately put to use much of their ill-gotten, illegal
2 and laundered funds derived from all of their criminal hauling and excavation operations, allowing
3 them to vastly increase the scope of their project, to maintain it at a higher level of efficiency for a
4 lot longer time, all of which damaged the Burl Tree more and more. Every additional day that
5 defendants illegal landfill took in new hazardous waste, more was sorted and placed onto
6 Remingtons land, where it was buried and further concealed with organic matter and mounds of
7 brush.
8 The basic financial process utilized by Olson and RAO was to invest their unjust profits from
9 their illegal hauling, dumping and excavation operations into the development of large new
10 residential housing developments in the Cutten, California area. That simple but elegant criminal
11 money-laundering operation involved building numerous $200,000-300,000 type residences and
12 then selling those usually through a bank, where Olson received payments and substantial interest
13 charges for life, in essence. As explained throughout these documents, the basic illicit RAO
14 criminal real estate model was simple, effective and very profitable and during discovery we will
15 gather additional actual facts, overhead and personnel costs and specific locations, dates and profit
16 figures, etc.
17 The present racketeering activity herein alleged, is involved in pursuing the enterprises
18 continuing objectives against Remington and also importantly is designed to cover-up the major
19 magnitude and severity of defendants original substantial underlying crimes, from the 1990s to
20 mid-2000s, as well as their subsequent uses of the substantial undeclared and laundered income, in
21 violation of 18 USC 1956-7 and 1961-4, et seq.
22 The latter statutorily cited damages appear to have been primarily to society, the local
23 community and to all levels of government, all of which indirectly damage Remington and he
24 therefore sues on behalf of those just named. Defendants non-disclosure and substantial evasion of
25 taxes at all levels, especially by the Mathsons and ALL of the RAO defendants, both named and
26 inferred, and therefore defendants money laundering uses were primarily an indirect injury to
27 Remington and the Burl Tree property. However, clearly there was some direct injury to Remington
28 and a balancing of the injuries, regarding who damaged who, when, where and how, due to
defendants obvious money laundering, and the multiple illicit uses derived directly there from, will
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1 be pursued further in future documents. For example, Remington already herein sues on behalf of
2 the public in several of the contamination causes of action and believes he can do similarly against
3 defendants for their tax evasion, either under said environmental statutes or the numerous related
4 whistleblower and other laws encouraging citizens to identify tax cheats. When Remington has
5 additional facts and evidence, and in the event that the relevant criminal or investigatory authorities
6 are not interested in that evidence, then Remington will otherwise augment his FAC in this case.
7 What is totally and emphatically clear today is that all of the top leadership of this alleged
8 RICO enterprise, plus all of the other paid members of it have all GREATLY prospered here from
9 the invested 1998 racketeering money and the numerous derivations thereof. A simple drive-by of
10 their houses, elaborate workshops and noting the very expensive vehicles which they all drive, is an
11 inference of what will be learned in discovery if we persist.
12 Again, this is a complicated, nebulous and sophisticated topic to determine who benefited
13 when, how much exactly and from what funds, whether legitimate or corruptly illegitimate.
14 However, even Gans as early as 2006-7 benefited from the Mathsons laundered funds from the
15 original crimes and all subsequent financial activity derived almost completely from both presently
16 involved insurance companies is also entirely based upon premiums paid with illegally
17 laundered funds, but intermixed with some possibly legitimate income sources. Similarly, it is
18 more than likely that Kluck and his Mathews law firm have also prospered from RAOs illegal
19 hauling and dumping schemes, probably going back into the 1980s or 90s when Francis Matthews
20 was still there, and Kluck may have been Olsons attorney for longer than we presently realize.
21 In addition to the funds used directly to impact Remington by virtue of better equipment,
22 more trucks and better maintenance to enable more debris to be imported and illicitly deposited
23 onto Remingtons land, all of the named defendants and many of the other alleged enterprise
24 members here have prospered in other ways and have all increased their quality of life, LEL,
25 improved their health stamina, strength and comprehensive support systems (I.e eaten and lived
26 much better) in order to fight Remington more energetically and effectively. Cumulatively, the more
27 money defendants brought in illicitly, the stronger they have become and that has hurt Remington
28 and the Burl Tree in itself in many obvious ways, which would include without limitation: Greatly
increased financial power made defendants more arrogant; more unfriendly; more imposing and
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1 litigious, less reasonable and entirely opposed to any negotiated compromises (since 2006); less
2 sensitive or empathetic; supremely confident and tougher; much stronger overall based on that
3 increased confidence, and that financial ability to hire meaner and more competent lawyers,
4 apprentice lawyers and personnel to enact or enforce their criminal schemes. In other words, as a
5 result of their above vastly successful criminal money making schemes, defendants therefore could
6 purchase any tools, equipment and supporting machines and materials, and then rent anything else
7 they could not afford to purchase, that they could conceive of, to use against Remington and the
8 Burl Tree, etc. Many examples of that have been cited herein and would include Mathsons fancy
9 flash cameras, several writing lawnmowers and sophisticated wood fence with carefully concealed
10 built-in secret doors that enabled him to trespass into Remingtons fenced security areas at will,
11 etc.
12 Future discovery in these cases will produce additional information which is needed here to
13 specifically identify which specific injuries were and still are attributable to illegal laundered
14 derivative income, and which injuries were/are caused by other factors.
15 12. If the complaint alleges a violation of 18 USC 1962 (b) then: (a) describe in
16 detail the acquisition or maintenance of any interest in or control of the alleged enterprise and (b)
17 state whether the same entity is both a libel person and the enterprise under 1962 (b). NA
18 No relevant present injuries are YET known or claimed under the statute as of late
19 2016, but that could easily change by the time of the FAC in this case.
20 However, there is much detailed financial information to learn from extensive discovery over
21 the next several years, especially regarding the RAO defendants, as alluded to above. Additionally,
22 Gans, Mathson, Randall, Lawrence, the City of Eureka, Kishpaugh, Brisso, Plotz, Nelson, the entity
23 which pays Kluck, and various others named herein, need to be examined in detail within the
24 context of 1962 (b) to examine and to trace all illicit funds derived from the original 1998 illegal
25 dumping and excavation projects, plus any other illicit activity and funds generated especially by
26 RAO, into definitively determine how said illegal funds and laundered monies were used, house by
27 house along Walnut Drive.
28 After that has been done, Remington and this court will attempt to reevaluate the honest facts
and circumstances on these sites to determine if his property and the Burl Tree were derivatively
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1 affected, and if so whether he was directly injured, or whether other neighbors and/or the
2 public was specifically injured here, beyond the public nuisances, trespasses and related broad
3 federal environmental allegations, already alleged herein.
4 For this document, and as of January 2017, based on present information it appears that
5 Remington and his businesses were not substantially damaged by new defendants businesses or
6 recently enterprise purchased derivative businesses, purchased with laundered funds based on
7 defendants 1998 and later crimes, DIRECTLY, however as alleged above, more indirect damages
8 absolutely did occur and their magnitude will be further evaluated during appropriate discovery.
9 However, in all probability, this innovative Mathson, residential hazardous waste dump was
10 not RAOs first roundup, i.e., not their first illicit venture of this type. There are other similar
11 illicit dumps known by Remington in the Cutten and adjacent residential Eureka area which RAO,
12 Joe Costa, other known gas station remediation contractors, and presumably many of the other
13 associated possible DOE defendants in this case were involved in prior to 1998. In other words, all
14 of the massive excavation and trucking equipment and overall significant financial power that RAO
15 used essentially against Remington and the Burl Tree in 1998 was also inferentially paid for with
16 prior illicit funds, derived from and based on prior as well as contemporary illegal activity.
17 If so, that may not be directly relevant in this federal case, because it is far outside of the
18 statute of limitations (here), however when civil and/or criminal authorities begin investigating all
19 of these related activities, presumably they will determine a much larger pattern of illegal dumping
20 and excavation activity than what is minimally alleged in Remingtons state and federal
21 contamination and RICO lawsuits.
22 Defendants believed and inferred substantial PRIOR criminal activity may not have statute
23 of limitations preclusions for civil and criminal authorities and if so, what said other investigators
24 discover, especially about RAO, and possibly the City of Eureka, Mathson, Randall, Costa, Hilfiker,
25 or Nelson of SHN etc., may have great significance in this RICO case over the next few years,
26 when it has all been discovered, however, not today in this statement, last cursorily edited in March,
27 2017.
28 13. If the complaint alleges a violation of 18 USC 1962 (c), provide the following
information: (a) State who was employed by or associated with the enterprise; and, (b)
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1 State whether the same entity is both the liable person and the enterprise under
2 Section 1962 (c).
3 (a) State who was employed by or associated with the enterprise:
4 1. As alleged and explained extensively above, Gans RICO enterprise does not
5 technically have employees or directly employ anyone on their payroll and take out deductions
6 for the enterprise, etc. Rather, the phrase associated with is much more appropriate and is the
7 most accurate characterization for most of the individuals named below. The top RICO leadership
8 located in the Mitchell firm might fall somewhere in-between the definitions in this paragraph.
9 Also, as has been discussed in considerable detail previously above, the employees, leaders,
10 non-affiliated individuals and individuals who belong to identifiable and legally significant
11 organizations, presently include, but are not necessarily limited only to: Gans, Plotz, Brisso,
12 McBride, the Mitchell firm, Olson, Skillings, RAO Construction, Nelson, Linda Lawrence of Allied
13 in Sacramento, John and Joy Mathson, Morgan Randall, both Kishpaughs, Boyd Davis of the city
14 of Eureka, RAOs insurer, Gwinn, Ferriman and their technician at Blue Rock Environmental; Kiff
15 analytical, Cal Science Environmental labs, Gary Costa, Martel, Esko, Liz Smith, Candy B, Judge
16 Reinholtsen, Kloeppel, Schwartz, Pulley, Hillyard, Conn, Dalka, Eads, Hilfiker, Kluck, Foget and
17 SHNs soil boring technician, Evans, Watt, Retzloff, and undoubtably other DOE defendants
18 expected to be discovered and added imminently at least by the FAC, when that occurs.
19 2. 1962 (c) reads as follows: It shall be unlawful for any person employed by or
20 associated with any enterprise engaged in, or the activities of which affect, interstate or
21 foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such
22 enterprises affairs through a pattern of racketeering activity or collection of unlawful debt.
23 This entire RICO statement is based almost entirely upon that statute, and to a much, much
24 lesser extent on 1962 (d) which follows in the interests of completeness, but is largely redundant.
25 The wording of that statute is very awkward, almost negligently complex, confusing and
26 essentially overly brief, however multiple re-readings of it and study make it relatively easy to
27 apply here, however it is somewhat complex, unwieldy and possibly wordy, to do so. Remington
28 has already taken almost 700 pages to attempt to fully explain this enterprise and what follows in
the next three pages is a non-repetitive attempt to further specifically interpret Gans RICO
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1 enterprise in terms of the above statute, to explain the numerous mostly corrupt relationships
2 discussed in these nearly 700 pages, and to yet again attempt to explain how and why each named
3 alleged enterprise member herein is guilty of something by their association here.
4 3. It is beyond the scope now to assign guilt or specific punishments to each member,
5 except to say that none of the named RICO Racketeering members above deserve no punishments,
6 and in fact not even close. It appears to be too late now to plead that we just didnt know or
7 understand and therefore we deserve to go free without punishment.
8 As described, Gans, John Mathson and Lawrence would deserve the most punishment here,
9 and some of those named peripherally are obviously not guilty of any crimes. However, at least 20-
10 30 of these named individuals are guilty of something by association, and because they committed
11 individual, provable actual criminal acts, and did not just irritate,rub Remington the wrong way
12 or commit multiple mere ethical or moral violations. More than 50 state and county laws have
13 been violated here by this group, PLUS more than 16 federal statutes, under 1961 RICO law
14 alone, and what punishments all of that deserves, will need to be determined on an individual basis
15 by future courts and juries, and certainly not here, now.
16 4. Russell Gans, Esq. and his 5-6 other primary ring-leaders lead this enterprise, and
17 for the previous 10 years have been exclusively financed by Linda Lawrence of Allied insurance
18 company. As discussed philosophically at length below, Lawrence and Gans during 2016 fully
19 direct and control this entire RICO enterprise primarily through their chief officers Plotz and John
20 Mathson, and without Lawrence it would all die 100% in seconds, and without Gans passion and
21 criminal intellect, it would also limp along indefinitely in wounded form, and then quietly and very
22 quickly die from lack of angry motivation, and criminal ruthlessness and nerve. Those facts, of
23 Gans and Lawrences indispensable significance to the enterprise, however seems to be quite
24 significant legally when one assesses criminal responsibility and/or will eventually adjudicate
25 reasonable punishments here in future years.
26 5. As a further specific response to (a) above: The other 30+ individuals described and
27 listed by names herein are all mostly intermittently paid by but are not technically employed by,
28 in the broadest sense, the enterprise at the various various times they are needed; but, since they are
fully committed and engaged with Gans above-stated RICO objectives, they are considered to be
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1 continuously associated with Gans at the enterprise, even while said enterprise is dormant, and
2 even when they are not assigned to any specific tasks. Many of the enterprise Associates wait
3 months or years between trials and specific assignments, which assignments may superficially
4 appear to be honestly and factually based; but when this court or anyone understands the true big
5 picture here, it can quickly be proven that all RICO enterprise tasks and assignments have been
6 easily proven to have an illicit, unethical or fraudulent intent and substance since about 2015, and
7 during 2016 most work involving Gans in these Remington cases, involved crimes, as alleged. Gans
8 and his experts did plenty of unethical, fraudulent and/or incompetent work prior to 2015, however
9 since then it is all much more substantially tainted and the majority of it is now provably false,
10 fraudulent or criminal, as discussed and proven.
11
12 (b) State whether the same entity is both the liable person and the enterprise under
13 1962 (c). NO, as explained throughout and as follows below.
14 1. Initially, there is no one person who is the enterprise entity or any entity, (or enterprise)
15 which is merely one liable person. In section (a) above we explained the significance of Gans,
16 Mathson and Lawrence especially, and explained that the enterprise would quickly die if any of
17 them did. However, that is not the same thing as equating anyone with the enterprise, although it is
18 somewhat close. In essence, what is really meant here is that this RICO enterprise has a foundation
19 of at least three tall pillars, Gans, Lawrence and perhaps the Mathsons. Remove any of those pillars
20 and the entire tower topples in a crumbled mass of dust, however the entire tower is the RICO
21 enterprise and those three spindly supporting pillars are far from identical to the entire tower
22 which goes up 5-10 times higher than the pillars alone. The nearly 700 pages contained herein
23 should adequately clarify that issue, among many other things, if one actually READS and
24 understands those pages, onerously long as they may be.
25 2. Similarly, there is no entity, and no one same entity, which is both the (only
26 one) libel person and also the enterprise. Semantical nitpicking, perhaps, but the detailed
27 meanings of words are important in the law. The above has all been pretty-well explained, as to the
28 leadership of a loose association of part-time associates who intermittently perform both legal and

645
1 illegal acts when ordered to by Gans. Therefore, we will not specifically reiterate all that again here
2 in different words and before.
3 3. Actually, in Remingtons view, this is essentially a trick question by the drafting judge,
4 presumably attempting to confuse, discredit and thereafter discard another frivolous, massively
5 complex RICO lawsuit where greedy attorneys are merely opportunistically seeking treble damages
6 for frivolous garden-variety tort, negligence or possible fraud lawsuits, which the courts obviously
7 seek to dismiss as early as possible and as frequently as possible. In any case, in the context of this
8 allegedly legitimate RICO cause of action, that question makes little if any sense in terms of this
9 particular enterprise which has been pretty clearly, if not concisely, explained and which has a
10 definite, discrete and very overt and apparent structure and hierarchy which is best understood by
11 studying the standard, graphical organizational box chart attached herein, in Volume III.
12 4. In this organization, as very thoroughly explained, Gans commands and controls it
13 all. But, like the one ring that controls them all, there are still at least 11 other rings which all have
14 their individual powers and importance, but under the one leader, Gans, the RICO racket is 10-100
15 times more powerful than if led by almost anyone else. Gans is in effect the battlefield general, Evil
16 Emperor and commander all in one with no one actually above him, for weeks or months at a time,
17 except for maybe Brisso at extremely limited moments. In other words, conceivably at pivotal
18 turning points, possibly Brisso or Lawrence acts as a higher commander-in-chief,very
19 occasionally, every few years, however essentially Gans is on his own making life and death
20 decisions all day long every day for months at a time. Probably, only Lawrence could now shut-
21 down this whole operation in seconds, fire Gans, dismiss the entire RICO enterprise and pay
22 Remington his just remediation expenses and now the other damages caused by these many years of
23 criminal activities against them. That is probably what she should do, or obviously what some of
24 her superiors should MAKE her do, if they are at all responsive to their stockholders, justice or
25 ordinary reasonable non-criminal behavior, as would be assumed.
26 On the other hand, to mix metaphors slightly, Gans does need to get funding and permissions
27 from Lawrence, analogous to the Defense Department needing to get funding from Congress, which
28 real-world reality actually means that Lawrence is the one that REALLY and ultimately controls
this RICO enterprise. Maybe it is she that is the real Godfather or Dark Lord here, possibly it is
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1 Brisso, as the leader in emeritus, but based on present careful, astute observations and thousands of
2 specific data points, it is Remingtons expert opinion that Lawrence REALLY runs this RICO
3 operation, and Gans is merely her operational CEO or acting general floor manager and supervisor
4 of all employees. In that scenario, she would be the Hitler, and Gans would just be the Goring or
5 Goebbels, etc. If that general situation is determined to be fair and accurate by the court, then
6 probably she should get the death penalty and Gans should be spared with life in prison only, but
7 in a nasty prison where he spends much of his time in solitary confinement, with no books, no
8 outside exercise and no TV, for at least most of the day, except for maybe one hour per day, or
9 TWO, if he exhibits good behavior for a few consecutive months.
10 The RICO racket operates rather obviously on only Gans ideas, schemes, devices, criminal
11 and general plans, and clearly it is he who is the operating Darth Vader military leader involved
12 in the Enterprises war against Remington, however, as we just discussed above, it is Lawrence that
13 would be the Highest command authority involved herein. Lawrence is the Dark Lord (wannabe)
14 that provides the ultimate direction, ALL financing, all military equipment, all logistics support and
15 also even brings-in all evil alliances by bribing them with endless funding (and gold), which
16 always seem to be necessary in these great wars.
17 5. What is the proof of that? Proofs are rather simple, logically and conceptually. Only
18 Lawrence can continue this war for 10 more years or she can end it in seconds (well, that is now
19 amended to maybe a couple of weeks) any day that she chooses, because it is patently obvious that
20 she pays all members, and none of them, especially Gans, will work more than a few days without
21 being paid. As further discussed below, there are a lot of other factors involved here, such as the
22 hope that the Lawrence gravy train would continue after a brief lull, and actually it would take
23 some sort of formal action or fear inducing punishment, to instantly close down this RICO
24 enterprise, because although it thrives on money mostly, at some point the fraternization,
25 excitement, thrill of torturing and destroying someone in the neighborhood and love of Gans,
26 Mathson and their friendly, charismatic and criminal leadership, ETC might keep this thing going
27 longer than would be expected, somewhat like a mens social club.
28 As above, Gans is exactly like Tolkien's one ring, that controls them all, but Lawrence
pays them all and only four known enterprise members would continue a few more weeks without
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1 being paid. Even in the Tolkien stories, no matter how many rings Frodo and Gandoff, et al
2 possessed at a given time, if nobody was paying and feeding the orcs and dark riders and everyone
3 else, no wars could be won. Lawrence feeds this Enterprises orcs and related cutthroats and
4 without her everything would stop instantly. At this point, now that Gans has such a finally-tuned
5 and trained group of co-conspirators in perjurers, theoretically Plotz could now take over and
6 continue leading this present band of trained lemmings right off the cliff, just a little faster than
7 Gans will inevitably do himself.
8 Those 4-5, or possibly a couple more, named a few pages back, Gans, Brisso, Plotz,
9 Lawrence and BOTH Mathsons would definitely continue on here, briefly without pay, just for the
10 love of the battle, the hate of Remington and because of their great fear of their crimes being
11 ultimately detected. Then there is that next group of original criminal perpetrators here who still
12 likely must dodge going to prison, and in addition to the above five would include Olson and
13 Skillings, McBride, Jeff Nelson and possibly Kishpaugh, Costa and/or a few of the other local
14 drinking gang and drug buddies, which also might conceivably and very briefly continue the war
15 against Remington for a few more weeks or months, without any additional pay, perhaps hoping
16 that the gravy train would start up again in a few weeks. A few of that long time, well-established
17 local gang would also likely be willing to go to prison for the wonderful Mathsons, which may
18 make it easier for them eventually, when convicted.
19 However the basic point remains that, when the money dries up from the pay-mistress and
20 Evil Emperor, Lawrence, the RICO organization will also dry-up very fast, but likely not
21 instantly as mis-described above. If the above group of 4-6 attempt to free-lance for a few weeks,
22 as would be anticipated, without Gans demonically clever, criminal evasive and concealment
23 instincts, legal cover, ethical pretenses and supposedly ordinary, honest civil defensive litigation,
24 the above group
25 would not stay out of jail for long, in Remingtons opinion.
26 6. Additionally, as specifically analyzing the 1962 (c) wording, clause by clause, as it
27 pertains to Gans RICO enterprise:
28 A. All of the named 35-40 individuals who are allegedly associated with this enterprise, are
also PAID by it, but as we semantically distinguished above, they are not really employed by it in
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1 the conventionally understood sense, but are more like private contractors, legally. Gans through
2 the Mitchell firm and their bookkeeping or secretarial staff pays most of them by check and is then
3 reimbursed approximately weekly by Lawrence from Sacramento. Although various members of
4 this enterprise may have other legitimate income and also illicit income from selling contraband
5 substances or other material, that would not be directly relevant to the Gans formulated purposes
6 and objectives against Remington, which are specifically focused and directed at these
7 contaminated dumpsites, and the often-repeated RICO objectives, which are:
8 Continuing to use Remingtons impacted lands at no rental cost; and continuing to
9 permanently STEAL approximately 1/3 acre of land adjacent to Mathsons backyard which he
10 should be paying rent for, at least until he can afford to buy it; continuing to appropriate and
11 ultimately steal all of the Burl Trees land as painlessly as possible; the avoidance of any cleanups
12 thereof or of Mathsons land; avoiding detection for their original crimes and subsequent cover-ups
13 and numerous new and continuing associated RICO crimes alleged herein; and, making sure that
14 the top management defendants, who exclusively control the enterprise and its corrupt activities,
15 AVOID going to prison, when all of defendants extensive criminality is fully revealed, etc.
16 It should be further noted that Gans, Lawrence, Plotz and Brisso presently exclusively
17 control this enterprise, prior to Kluck and RAOs insurer taking a more central and possibly more
18 powerful role here. Since RAO is at least as guilty as the Mathsons and probably at least 10 times
19 more so, it can be expected that during federal discovery here Kluck, Olson, Skillings and a new
20 array of additional RAO DOE defendants will probably become prominent here, but could never
21 fully wrestle the RICO leadership away from Gans and Lawrence, who both have made careers and
22 a lifes work out of these cases.
23 Note also that the afore-named enterprise leadership does not care one bit about what
24 happens to the Mathsons, Kishpaughs, Randall, Nelson, Plotz, Costa, Hilfiker, Hillyard, Ferriman,
25 et al, or probably any of the other members mentioned by name here, who will all eventually be
26 implicated to various degrees here, and then fall like a tall tower of cards when the central,
27 controlling leadership is eventually indicted.
28 B. Does the enterprise employ Gans? Not as such. Gans is not the entire enterprise but

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1 for weeks at a time sometimes he is the only active member of it, at all, except for Plotz and
2 possibly John Mathson, who never really soundly sleeps anymore and dreams about attacking and
3 destroying Remington, 24-7. Since Lawrence exclusively pays Gans and therefore employs him, as
4 one would pay or employ a licensed private contractor, she is the enterprise in one sense, but not in
5 accordance with our main definitions. On the other hand, Gans also works for the Mitchell firm
6 under some unknown compensation formula based on hourly time sheets, so in another sense,
7 Lawrence just pays the Mitchell firm, and arguably then they might be solely responsible for all of
8 this. Some of these questions are not readily or fully answerable, now or possibly ever, but they
9 make interesting philosophical debate, which we are happy to participate in, here and eventually
10 with the court.
11 This fall 2016 analysis, which preceded most of the above subsequent and perhaps more
12 thorough analysis, would appear to indicate that the enterprise may employ or at least pay as
13 private contractors, most of its members, however Lawrence and possibly Gans also, appear to be
14 somewhat apart from that. They, at least Lawrence anyway, are compensated and receiving other
15 benefits from their corrupt activity as a matter of course based on some sort of a legal structure
16 within an insurance company, which is independent of the enterprise and very likely does not even
17 understand YET that an enterprise exists in this situation. Gans and Lawrence are the backbone
18 brains and nervous system of the enterprise, but require the other 35+ or so members to make it all
19 work, as was much more clearly explained above, and repeatedly at that.
20 C. Lawrence is paid by other bureaucrats above her in her Sacramento hierarchy, and
21 she is presently believed to conduct her work and oversight of the enterprise ostensibly legally and
22 under the guise of a defensive liability insurance policy, gone amuck. Her exact situation,
23 responsibility, culpability and liability here will undoubtably be the subject of vastly complex
24 higher insurance law which is well-protected by thousands of insurance lobbyists and thousands
25 of favorable Supreme Court precedents. At the proper time, those will be studied and addressed if
26 necessary.
27 Meanwhile, it is self-evident that nothing that Lawrence does now, on an objective scale, is
28 honest, ethical, JUST, reasonable, legal or defensible but appears to only be consistent with her past
actions, and hence is solely based on bullheaded momentum, bitterness and dislike for Remington,
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1 collateral estoppel, determination and inferentially hate for independent men or towards anyone
2 who opposes her will. Those traits in a few more were clearly observed, evaluated and noted when
3 Remington met her in person, in 2010 and had other interactions in 2011.
4 Presumably if Remington was a pleasant, easy-going, weak and cute young woman, this case
5 would have long been over and Gans RICO enterprise never would have been necessary or begun!
6 For years, Lawrence has been financing an iffy and borderline defensive operation which has
7 now entirely crossed-the-line into a terrible, violent, ruthless and untoward criminal racketeering
8 world, which she is now knowingly financing. It therefore seems rather obvious that anything
9 bad, violent or unlawful which occurs from January 2017 on, is entirely her responsibility. She
10 alone can stop all this racketeering activity. Only she has the power to stop this RICO criminality
11 instantly, or she can continue to support and fan the flames and whatever burns down in the fire
12 now is exclusively her responsibility. When she stops paying Gans to support and continue his
13 RICO battles and major war against Remington, it will stop very quickly as discussed above.
14 If violence should not unforeseeably be committed against Remington in the next few months
15 or if one or more of the enterprise members decides to silence someone in their gang, in order to
16 save themselves from indictment and possible prison terms up to 20 years, then who would be to
17 blame here? Gans is just doing his job, as he characterizes it, drawing his pay and working at his
18 highest level of competency, which in this case has been inadequate for years. It is true that he has
19 become a zealot combatant and does not have the objectivity that outside defense counsel should
20 possess, so as a result he has only the sole objectives named which involve himself getting paid
21 indefinitely and keeping these cases alive forever, at least until the Enterprises objectives have
22 been reached and hopefully fully obtained.
23 D. Where is Allieds middle to upper management in all this? Do they have an adult
24 overseeing these cases, that supervises Lawrence?
25 A careful analysis of these cases, including the Gans-Lawrence RICO enterprise must
26 conclude that neither of them have any objectivity left, competency or motivation to ever ethically,
27 justly or fairly resolve these cases against Remington, and therefore THEY will continue with all
28 this until they either WIN unconditionally, or are indicted. Another option is that Lawrence is not
acting alone and she may have 2-3 others as guilty and complicit here, or more so, than she is
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1 alleged to be herein. Imminent discovery will explore that area fully, complete with anticipated
2 MANY motions to compel.
3 Remington presently assumes that there are 3-5 management and executive levels above
4 Lawrence at that insurance company, from Sacramento to Iowa, and that possibly this RICO case
5 will be a wake-up call for someone older, wiser and more ethically grounded, to take a look at all
6 this legally and perhaps put an ethical attorney above both Lawrence and Gans to interview Gans
7 especially and interrogated him about Remington specific allegations herein. This could go on for
8 another 10 years, or perhaps someone at Allied will overrule Lawrences improper decisions, which
9 now amounts to her and Allied paying-out virtually unlimited funds to the RICO enterprise.
10 Someone at Allied or possibly at RAO-Klucks insurer going forward might want to take a
11 reasonable and fresh view of these litigations, because once the federal court and investigatory
12 authorities get involved here, then this will be out of everyones control.
13 Additionally, Remington will be amending both of his successive action state complaints as
14 time permits to add a RICO cause of action appropriate to the statute of limitations and different
15 governing law in each case.
16 E. We have established above, that any enterprises effect on Remington or the Burl Tree
17 has a significant effect on interstate commerce. Not necessarily a substantial or momentous effect
18 but since the Burl Tree is a well-established and significant business entity, and because it currently
19 does all of its sales interstate, any deleterious activity against it affects interstate commerce by
20 definition.
21 The RICO statutes and thousands of related and applicable RICO interpreting precedent cases,
22 do not require Remington to affect interstate commerce like China, Japan or even Ford Motor
23 Company or Sears, that have stores in multiple states and countries.
24 Some or any measurable effect on interstate buying, selling or other related dynamics is
25 sufficient and Remingtons well-established Burl Tree easily satisfies those criteria.
26 F. RICO leaders and/or employees. Similarly, all named aforementioned RICO enterprise
27 members either conduct (direct, or supervise, as designated) or at least participate-in, either
28 directly, indirectly or both, as soldiers or part-time employees, in the Enterprises affairs. As
fully explained and logically proven above, said participation and enterprise conduct is intended to
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1 unjustly and wrongfully WIN these cases unconditionally; Destroy, torture and/or otherwise
2 torment Remington as much as can be discreetly accomplished; Make lots of money for all
3 members, especially Gans, who has based his entire career on the Remington matter; and,
4 avoid detection and imprisonment, for as many members as possible, and especially Gans and
5 Lawrence. After that, who really cares?
6 None of the alleged RICO enterprise members would have been mentioned or discussed here
7 at all if they did not directly participate in the enterprises activities in pursuit of its objectives, by
8 carrying-out conduct which was fully paid for by Lawrence and specifically directed by Gans, and
9 his fellow inner circle leadership, either directly or through his above-named further intermediaries,
10 and always in full pursuit of the enterprises multiple purposes and goals, discussed above.
11 G. Gans RICO enterprise acts through a pattern of racketeering activity, not all of the
12 time but enough of the time to be culpable here.
13 As alleged in considerable detail, and with sufficient specificity, Gans immediate subordinate
14 helpers, associates, partners, assistants, soldiers and enforcers have provably engaged in the
15 detailed patterns of illegal state and federal RICO predicate acts alleged above. But for Gans
16 predicate acts and related extortive racketeering activity, Remington would not really have had to
17 pay serious attention to Gans bogus, unscientifically based defense, because it was frivolous all
18 along, and would have been defeated long ago, if it had been honest, fair and conducted according
19 to California contamination remedy law.
20 Further, as explained, the Enterprises actually felonious and federal law violations are
21 discontinuous and somewhat isolated. That makes explaining the above bold heading somewhat
22 more ambiguous, because Gans enterprise does not act only through a pattern of racketeering
23 activity, but it certainly does it frequently and seriously enough to make Remingtons conventional
24 offense ineffective and to require this RICO action to attempt to reach a just result here.
25 In other words as explained above, Gans actionable federal predicate RICO violating acts are
26 surrounded by and at times inundated by a plurality of hundreds of related unethical but non-RICO
27 predicate acts, which are also interspersed among many thousands of reasonable, or somewhat
28 normal litigatory acts against Remington, all over the course of about 10 years. Gans numerous
non-predicate acts and ordinary non-corrupt paragraphs in his letters and motion documents are in
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1 essence distractions and analogous to dummy warheads launched by an ICBM to defeat
2 antimissile systems, where there may be only one or two real destructive warheads, surrounded by
3 20-100 fake warheads, but which are not recognized as such by radar. All Gans communications in
4 recent years always have at least several real destructive warheads surrounded by benign
5 material, and it is those warheads which are objected to here as state and federal crimes which are
6 reddressable under RICO. However, recall the legal truism cited above, that Gans and all his
7 enterprise members can theoretically perform 10,000 legal or altruistic acts of charity, but perhaps
8 only two provable extortions or one murder, plus one provable incident of obstruction of justice
9 during a 6-12 month period. However, only 1-2 or a few serious criminal violations can easily
10 and completely erase hundreds or thousands of legal activities, and that is exactly what Gans
11 enterprise has done here.
12 H. Essentially the only activities fully relevant in or to this RICO case are the 30-50
13 obvious federal predicate act violations, plus the scores of additional fraudulent and mostly
14 illegal acts that have been committed by defendants here, which serve as a background to view
15 their criminal acts against, and to highlight them in effect. In these documents, Remington has
16 begun to paint the background and isolate and distinguish the federal crimes from that generally
17 unethical background, but he has not yet fully completed that task. Much work remains involving
18 sorting- through and analyzing all of the other detailed mail and wire violations contained in the
19 tens of thousands of pages from the five (5) previous and presently ongoing state and federal
20 lawsuits, involving these generally similar, related and overlapping issues on these adjacent
21 properties.
22 Importantly, many of defendants numerous other fraudulent, unethical and unlawful written
23 acts which were communicated by mail or wire are initially only violations of county and state
24 laws, however they will soon and very imminently become violations of federal civil and criminal
25 law, subject to fine and imprisonment just as soon as Gans in his large array of culpable witnesses
26 begin responding to intensive federal discovery. The reason for that is quite obvious.
27 Gans and his entire perjurious group, must now going forward be consistent in this federal
28 case, in all of his future federal written and oral discovery responses, with his now well-established

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1 corrupt perjury-based evidentiary state trial, state deposition and special interrogatory record
2 which he has consistently and falsely maintained and escalated now for more than eight (8) years.
3 Culminating in summer 2016, every year Gans evidence and witnesses have become
4 increasingly false and incompetent to the point where his defense has been reduced to factual and
5 truthful absurdity today, when it is all clearly understood, properly presented and explained.
6 Remingtons job now and that of his counsel is to do exactly that.
7 I. Although the statutory wording of 1962 (c) is nebulous, excessively, and therefore
8 meaninglessly brief and not clearly written; nevertheless, this entire Remington RICO statement
9 document explains in detail how all enterprise members violated that general federal law to the
10 varying extents alleged, either directly or by association, and through their leadership, other conduct
11 or participation in the numerous specific federal law violations alleged, all of which affected the
12 Burl Trees land and property and reduced the Burl Trees interstate commerce sales and profits to
13 nearly Zero, as a result.
14 This RICO action should be allowed to proceed now because Remington has alleged and
15 essentially proven at this preliminary stage that defendants committed and/or violated several dozen
16 federal predicate acts, whereas only two, in accordance with the other companion requirements, are
17 necessary to prove the existence of an actionable RICO enterprise.
18 Accordingly, the burden now shifts to Gans, defendants and their associated attorneys to defend
19 and attempt to exonerate themselves. Alternatively, they can resign from the enterprise, disassociate
20 themselves from Gans and his fraudulent, incompetent and perjurious legal defenses, or just demure to
21 this complaint, move for its dismissal and then shortly thereafter properly respond to and answer this
22 complaint, its causes of actions and RICO allegations, respond to discovery, defend themselves and
23 thereafter join with Gans corrupt enterprise to fight Remington in San Francisco federal court.
24 14. If the complaint alleges a violation of 18 USC section 1962 (d), describe in
25 detail the alleged conspiracy.
26
YES, violations of 1962 (d) are alleged, but since they appear to essentially entirely
27
overlap with 1962 (c), at this point; and, further in view of the fact that no RICO Case
28
Statement such as this one, in approximate 680 pages, is even required initially at all by this court,

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1 Remington therefore declines to repeat 30-40 redundant pages here now. If and when some clear
2 distinction appears between what is alleged in (c) and (d) in the near-term, Remington will
3 promptly supplement this statement with any new information pertinent specifically to (d), which is
4 not already included herein.
5 15. Describe the alleged injury to the business or property.
6
There have been over 20-pages above almost solely devoted towards describing various types
7
of damages two Remington allegedly caused by Gans RICO racketeering enterprise.
8
9 Beginning with footnote 1 on page 2, the background on page 8; the major extortion
10 damages deriving from the Figas threats and intimidation on pages 12-13; various types of land
11 injuries on pages 15-16; Gans related damaging rackets on pages 23-26; SHN caused damages on
12 page 53, etc. The main complaint describes other kinds of damages throughout and especially in its
13 last section. [Those page numbers were accurate several months ago and cannot be confirmed today
14 due to excessive crashing of this program when several hundred pages are toggled at once].
15 Here at this section therefore we will summarize most of them only.
16 A. Defendants have effectively and permanently stolen about 1/3 acre of Remingtons land.
17 As explained above, more than one third of an acre of Remingtons property has been directly
18 impacted by defendants dumped and buried hazardous materials and scores of other adverse toxic
19 and contaminated materials which are specifically named throughout the complaints, and are well-
20 known to all defendants. The gigantic reinforced concrete blocks up to 20,000 pounds are also
21 highly objectionable in their own right as ugly and immovable boulders in the middle of
22 spectacular rose and exotic plant gardens, under the spectacular canopy of a pristine and near-virgin
23 redwood forest.
24 Additionally, at least acre overall on Mathson side of Remington Creek, including all
25 land directly downhill from Mathson landfills have been seriously damaged and substantially
26 ruined, user directly by contaminated soil migrations and slides or from the various types of
27 contaminated water reaching there by gravity flow.
28

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1 Therefore, the entire area north of the creek plus the creek itself is seriously polluted with,
2 among many other toxins: soil and waterborne hydrocarbons, asbestos, lead and highly poisonous
3 and infectious untreated sewage residues from Mathsons unpermitted backyard septic systems.
4 There have also been numerous slides over the years, including in 2017, caused primarily by
5 Mathsons twin 6-inch drainpipes, as documented in previous complaints, each of which slide lost
6 large volumes of topsoil, mulch and many valuable plants into the creek (and then the bay and
7 ocean) and required sophisticated and expensive measures to stabilize and rehabilitate, not yet all
8 completed.
9 That damaged and ruined land alone, with its fertile native soils, thousands of rare planted
10 trees and bushes under more than 50 large redwoods, is worth approximately $150,000 by itself.
11 The additionally damaged land below THAT, north of the creek is worth another $75,000 to
12 repair or clean-up;
13 B. If defendants do not buy the above-described one-third of an acre, then they should
14 be paying rent of at least $1000 per month for the land they are directly occupying adjacent to
15 their backyard and valuable structures, because Remington is unable to use any of that land
16 for anything. Defendants therefore owe more than $228,000 of back rent currently in 2017,
17 which money has been demanded for several years, as discussed further below.
18 The Mathsons developed their entire property with huge lawns, several large permanent
19 sheds, major landscaping and a giant 3-5 car garage all on the southern edge of their land. All of
20 that aforementioned developed land would be instantly lost in a few hard rains over 1-2 years,
21 WHEN, or if Remington removes the Mathsons encroaching 600-1000 yds of supporting
22 materials, which they dumped there in 1998 to provide lateral support for their future development.
23 Said 600-1000 cubic yards of polluted and hazardous wastes are 100% on Remingtons exclusive
24 land and acts as a pyramid base supporting the more than 3000 additional cubic yards of Mathsons
25 fill at the top of the mountain.
26 A retaining wall about 10-15 feet tall at the property line is now needed by Mathson to
27 support their property after remediation of Remingtons land below, however they are unwilling to
28 negotiate or build one, so a court injunction to order same has been requested herein. They are
anxious to complete the new fence to be built by Miller Farms which funds were extorted from
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1 Farmers Insurance by Gans and defendants as part of their $20,000 settlement, however without
2 first putting in a foundational retaining wall, all of the proposed fence work will be lost after
3 Remington removes the first 10-20 yards of debris below said fence. Said above fence right now
4 will be built substantially, and for about 150-feet, on top of 5 to 15 feet deep fill, which is unstable
5 and will all collapse when Remington removes the hazardous wastes below the property line.
6 That removal of defendants hazardous wastes is expected and projected to occur after the
7 first jury verdict in one of the contamination trials scheduled either in the state or federal system.
8 However, Gans enterprise is in the process already of prematurely building their ill-advised chain-
9 link fence on top of no proper foundation, which must be engineered into native soils, but rather on
10 top of footings consisting of filled random debris (as named herein), which will absolutely
11 imminently collapse during remediation, spawning a new round of litigation, due to defendants
12 deliberately ignoring the above analysis, which has been clearly explained and presented for at least
13 five or six years by our engineers, including Remington who is an engineer.
14 Presently, as one of the primary objectives of the enterprise, these litigations are still
15 brazenly scheduled to never-end, until Remingtons land is remediated, and therefore Gans and the
16 other RICO racketeering gang will continue to be paid here indefinitely, in a continuum of one
17 lawsuit after another.
18 Defendants have a dangerous adversity for proper engineering. They did not engineer their
19 illegal filling project at all in 1998, and now they have predictably started their fence project in a
20 similarly improper, unsustainable and half-assed manner, which fence will obviously collapse as
21 explained above, and may collapse before that because they cant properly set chain-link fence
22 poles deep enough or stably into that type of rubble of solid chunks of asphalt and concrete etc. The
23 writer of this section, Remington, was an Alfred P. Sloan National Scholar in engineering at Cornell
24 University, and additionally practiced various diverse structurally-related excavation, hydraulic
25 and metallurgical engineering disciplines, directly applicable here to the basic physics statics forces
26 on these very steep properties, for about 40 years thereafter. Most of which engineering,
27 construction, excavation and general contracting building experience is directly relevant to this
28 analysis. In other words, Remington is an engineering expert in regards to the simplistic statements,
plans and general designs expressed above and defendants refusal to pay any attention to
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1 elementary engineering principles along the boundary line is nothing less than additional criminal
2 negligence, which is guaranteed to damage Remington further in all of these present and ongoing
3 litigations.
4 The premature beginning of the agreed-upon fence along the Mathson-Remington boundary
5 has been previously alluded to as a predicate act, whereas defendants failure to build a retaining
6 wall has not yet been cited, but it already has caused measurable additional contaminated landfill
7 movement damages, which cannot yet be fully numerically determined until summer, when all rains
8 stop.
9 Before long however when remediation does eventually start here, predictably there will
10 be other damages to Remington, the lower property owner, as partially explained above, which in
11 the next version of this RICO statement will probably be characterized as a state or federal criminal
12 violation, after a licensed local, retaining-wall engineer is consulted, and the appropriate excavation
13 laws which are intended to protect downhill property owners, which have been violated here for
14 years, have been fully discovered and interpreted. We already know and have proven that
15 defendants violated more than 30 County excavation permit and development requirements, but
16 have not researched state or federal violations yet, which probably also exist here. WeExpect to get
17 to that in the next few months.
18 C. However, the main economic damage to Remington and the Burl Tree with respect to
19 all of the allegations in the federal lawsuit, involve the rest of the entire property of several acres
20 which is now unmarketable and unsalable, while any portion of the property is contaminated and
21 waiting for draconian action by regulatory authorities. If Remingtons property was remediated and
22 free of all asbestos, hydrocarbons and the other hazardous wastes which Mathson and defendants
23 buried on Remingtons land, then even today in its uncompleted state it would have a market value
24 in the million-dollar range. Further, after another $100-200,000 of final finishing both inside and
25 out, according to plans and palatial specifications, the future sale value or value to the public for use
26 as a park could be arguably $5-$8,000,000, on the international real estate market. The plans,
27 executed ornamentation both inside and out are very special and based on the great houses and
28 palaces of the world, and primarily employ French Gothic cathedral ornamentation. Not that much
is left to do either inside or out, except for a lot of final finishing. Probably not on the scope of
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1 Scottys Castle, the California state park or national Monument, but as for California and
2 certainly any development north of South San Francisco, Remingtons development here is
3 different, unique, very spectacular and holds tremendous artistic and remunerative promise when it
4 is finally completed.
5 Meanwhile, with the land in its contaminated condition the overall value of the estate is
6 reduced by at least $300-500,000, but as just stated above, very arguably the diminution in value is
7 more than that because the whole property is really unmarketable now at any price according to
8 Remingtons real estate experts and appraisers. The cost to cure theory espoused by Remingtons
9 expert Tidwell is all well and good, except when the inevitable stigma is factored in and ADDED,
10 plus the possible dangers of future Water Board or County-ordered higher standards of cleanup are
11 considered, if remediations here are on un-indemnified. Overall, we are using a $400,000 property
12 value reduction in this estimate, as to rehabilitation, stigma and future indemnity RISKS. Since
13 stigma is not necessarily automatically recognized in California law, Remington now anticipates
14 selling the property in 5-10 years and then comparing the international sales price against several
15 expert appraisals of that type of international property, and thereafter suing to recover any obvious
16 or prejudicial loss attributable to stigma, assuming that no other factors are present.
17 D. Another major damage which was discussed herein, involves Remingtons now
18 stymied plans for easily achieving his dream and critically important public community
19 service, of harnessing Remington Creek and its 50-100 million gallons of presently wasted water
20 flows per year, which Remington had planned to use for local drinking water use. That water will
21 eventually be needed here locally for drinking, assuming present drought conditions continue as per
22 the last 50 or so years. With exact profits and value dependent upon where the water is sold, under
23 any scenario there is a lot of value in having that amount of water here locally in tanks with pumps
24 capable of distributing it as needed.
25 Including the retaining wall, and proper treatment of the (above) proposed captured
26 underground and surface contaminated waters emanating from beneath Mathsons landfills on both
27 properties, right now a minimum of $300,000 is needed to maybe fully restore the land and to
28 hopefully convince the regulatory authorities that the imminent threat and danger to the surrounding
environment has been alleviated, both now and going forward. Once the water is cleaned-up to
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1 drinking standards, Remington and the real owner The Burl Tree will then have a very valuable
2 additional asset flowing down Remington Creek, which he will capture, store in large on-site tanks,
3 and then pump up to Westgate for use as needed.
4 E. BACK-RENT IS ALSO NOW DUE OF $228,000.
5 Reasonable rent of $1000 per month was discussed at B. above, which is a mere $12,000 per
6 year to preserve all of Mathsons land, property and residential structures worth several hundred
7 thousand dollars. Without the lateral supporting Remingtons property, wantonly stolen by the
8 Mathsons, which was unwillingly surrendered by Remington and the Burl Tree, and then which
9 defendants extorted, and continue to extort in order to keep it permanently, Mathsons entire
10 property would collapse into the ravine very quickly, as explained above. Accordingly, Remington
11 for several years has demanded back rent since 1998 for the involuntary use of his good land by the
12 Mathsons. 19 years times $12,000 per year equals another $216,000, which Mathson and
13 defendants owe Remington in these lawsuits, which sum is still going-up by another thousand
14 dollars per month in 2017. That sum is now due, payable and herein is again DEMANDED.
15 F. The Burl Tree also has at least a $600,000 inventory of redwood burl, and about 10
16 other varieties of burl in lesser quantities, especially dry Maple and Buckeye burl. Also, the Burl
17 Tree has more than $50,000 of valuable used machinery, salable equipment and fixtures, including
18 an enormous hydraulic pole mill capable of cutting moral slabs up to 12 feet wide and weighing
19 several tons, a Silverado pickup with hydraulic crane, a good forklift and numerous usable used
20 three-phase electric motors, hydraulic power units and related controls, piping, mill feed tables,
21 conveyors, etc.
22 There is also another 20-$30,000 of salable scrap iron, including I-beams, H-beams, steel
23 rails and mill carts, a heavy solid steel trailer, two 800-pound fork lift forks, one 12,000 pound
24 loader bucket, etc.
25 During the 10-year course of these lawsuits, and the necessity of Remington defending
26 himself and the Burl Tree from Gans and his RICO enterprise, the Burl Trees outside inventory has
27 depreciated at least $150,000 from its former value of over $750,000. All of it could have been sold
28 back in 2014-15 to Mick Jagger, and his partners, headquartered in Boulder Colorado, and also
directly or indirectly to his wholesale associates, scattered around the United States and other parts
661
1 of the world, such as the Philippines and China. Jagger represented that he had all of Remingtons
2 inventory sold to himself and his Colorado associates, and the remainder could be sold to said
3 Philippine contact, however said sale was permanently lost when Remington lost touch with them
4 due to serious full-time occupation with these lawsuits and specifically having to defend against
5 Gans frivolous 2014 collateral estoppel summary judgment. Remington estimates that permanent
6 lost opportunity is a damage of $368,000 in 2017 US dollars. The TOTAL loss above = $150,000+
7 $368,000=$518,000
8 During that period in December 2014-January 2015 Remington did two major wholesale
9 deals to Jagger and shipped thousands of dollars of slabbed burlwoods to him by truck, but we
10 never had the time the schedule a major visit or the time to mill-up further burls, or send samples to
11 the Philippines etc. We were exactly geared up to do that when Gans filed his frivolous collateral
12 estoppel summary judgments. Hundreds of pages of emails, invoices and business records relate to
13 these interactions, but the bottom line was that Remington was too busy defending the Burl Tree
14 from the enterprise and lost touch with Jagger and his associates, causing a total damage to the
15 Burl Tree in permanently lost sales, depreciation, inventory deterioration and nonrenewable
16 opportunity costs of approximately $518,000. If another sale of that type materializes then possibly
17 half of that could be redeemed, however at this point Remington finds that unlikely. During the past
18 several additional years of deterioration in the weather, after hundreds of tons of burl were
19 prematurely exposed for sale to Jagger and for photography and milling, probably $160,000 of
20 additional permanent deterioration of the inventory has occurred. Several years from now when
21 final damages are calculated in these cases, the possibility that some of the facts have changed in
22 regards to that number will be evaluated.
23 G. Additionally, there has been an enormous drop in Burl Tree sales because Remington
24 had to defend the Burl Tree against Gans Enterprises frivolous lawsuits, plus attempt to remediate
25 and restore the value of the Burl Trees land in terms of Remington several offensive lawsuits.
26 When Remington is litigating against Gans frivolous RICO lawsuits and defenses, Remington is
27 not making inventory or selling it to customers one-on-one. Remington can only do one of those at
28 a time and for the last several years he has been defending against the RICO enterprise and not
selling burl.
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1 But for defendants unlawful contamination of his property in 1998 and beyond, none of these
2 lawsuits or legal expenses would have been necessary or expended and hence under the doctrine of
3 recovering damages for all detriment proximately caused thereby, defendants owe Remington
4 for lost Burl Tree sales as well as for the reasonable value of his time at a minimum of at least
5 paralegal and/or executive secretary rates, such as whatever McBride earns. 10,000 hours at
6 McBrides rate of pay would not begin to compensate Remington for his efforts in these lawsuits,
7 but is hereon requested as a minimum additional recoverable damage. Remington will argue all the
8 way to the Supreme Court that his time is worth at least whatever McBrides is for defending
9 against a RICO enterprise.
10 The Burl Tree has lost an enormous amount of sales since the discovery of defendants
11 pollution in 2006. During 2006 and in the prior 20 years Burl Tree sales averaged approximately
12 $100,000 per year, and have been as much as $400,000 in a year. Today, and since about 2008, sales
13 have been roughly in the $4000 per year range. That is a drop of about $96,000 per year attributable
14 to these lawsuits, and Remingtons forced participation to defend against a criminal enterprise, as
15 opposed to just conducting good old honest and civil litigation.
16 As established elsewhere, because the Burl Tree IS Bruce Remington, and because
17 Remingtons time has been 100-110% occupied full-time 5-6 years here, Remington attributes
18 about $45,000 per year in lost sales to the necessity to defend against Gans lawsuits alone over the
19 past eight years. The other half of the loss of sales is not claimed here which was attributable to
20 Remingtons own offensive litigations, even if they were corruptly defended by Gans. Although,
21 arguably all of Remingtons litigation time spent defending the Burl Trees property interests should
22 be recoverable, as well as loss Burl Tree profits, there are other assumptions which can and have
23 been made here.
If only Remingtons time spent defending against Gans frivolous motions and lawsuit are
24
recoverable here, one could argue and rounding down in defendants favor, that 8-10 years of
25
diminished profits of almost $90,000 per year if calculated at $720,000, then if that is divided by
26
two to recover only defensive time but not offensive case time, then only $360,000 in lost profits
27
would be recoverable, plus $8000 additional costs. Whether Remingtons paralegal or secretarial
28 time is added-onto that number would be a matter for the trier of fact to determine at some later
appropriate time.
663
According to the above calculations, the enterprise directly reduced Burl Tree retail sales by
1
about $368,000, and wholesale sales by a total of more than $500,000, for a total of $868,000,
2
according to proofs. About $850,000 of that loss would have been in interstate commerce.
3
Not a major drop to the US GNP or world economy, but very major and catastrophic to
4
Remington, his family and the Burl Tree plus thousands of deleteriously affected customers, USA
5 and world-wide.
6 Additionally, there is some subjective overlap between the estimates at letters F and G above
7 regarding total estimated Burl Tree sales, profits and balanced by estimated lost wholesale sales for
8 burl and related products, and the possibility exists that some individual, small wholesale or jobber
9 sales might be made-up sometime in the future.
10 This is admittedly a complex and somewhat subjective calculation and in any case Remington
would not expect to be double compensated for his time conducted drafting and executing legal
11
documents, such as they are, and also for lost Burl Tree sales, when or if those lost sales were being
12
compensated at some lesser legal rate. In other words, Remington often makes hundreds of dollars
13
(or more) per hour working in the burl industry, but would not expect to make more than $35-75 per
14
hour as a legal worker, although by most objective measures, Remington should be worth as much
15 as Plotz, to say the least.
16 H. Finally, Remington does have numerous other categories of damages especially
17 general damages for personal injuries and various types of emotional damages including those
18 which are specifically recoverable under trespass, as delineated elsewhere, and All damages are
19 most completely listed at the end of the main federal complaint.
20 16. Describe the relationship between the alleged injuries and violation of the
21 RICO statutes. Gans RICO racketeering enterprise has caused many additional damages and
22 also substantially aggravated the initial contamination damages alleged since 2006-2008.
A. Initial contamination injuries. The primary initially alleged injuries to Remington and
23
the Burl Tree during the 2005- 2012 period, were exclusively caused by the original environmental
24
violations as addressed in the earlier state cases and now in the primary federal complaint here;
25
however, since about 2012-13, the RICO violations have augmented, perpetuated and otherwise
26
greatly increased the above damages and made remediation much harder, and much more costly,
27 for example because additional debris continuously slides further down the mountain, some of
28 which is now out of reach of any machinery near the top of the mountain, and even from the bottom
of the mountain. Whereas the middle of the mountain is entirely inaccessible to large excavators,
664
backhoes or any machinery. Therefore, some debris will now have to be removed from the creek
1
and its environs by hand and packed-out to the bottom excavator landing area, above the swamp.
2
Additionally, as complained herein numerous additional severe damages of all types have occurred
3
to the Burl Tree property and to Remingtons personal health, which damages will have to be
4
carefully differentiated and divided between the contamination allegations and the RICO claims.
5 Remediation of the lower swamp area along the Ridgewood right-of-way, has therefore also
6 become necessary and will increase the overall costs substantially, because a separate landing and
7 road off of Ridgewood Drive will now be necessary, in addition to moving about 100 major trees
8 and plants; plus, at least two enormous logs will now need to be sawed-up and/or removed.
9 B. Additional and aggravated injuries caused by the RICO enterprise. Ascribing specific
10 economic damages to specific RICO crimes or individually violated predicate acts is somewhat
difficult, subjective, and will need to be further specified, identified and better quantified in the
11
FAC. The next several years of discovery will also be needed to fully clarify this issue before trial,
12
but nevertheless Remington will now attempt to make the best possible estimates, at this time.
13
C. Renz decision is now vitally needed here. Without a formal Renz decision as explained in
14
the next paragraph below, not even a valid approximate guesstimate is possible, as any of the below
15 subtotals could double or triple over several years, while awaiting a trials, appeals and beyond.
16 ONLY after substantial discovery, proofs one or more trials in either state or federal venues,
17 and very importantly a final RENZ (Renz v. 33rd District agricultural Association,1995, No.
18 H011907, Sixth district) ruling48 is issued for one or both courts, which effectively will determine
19 in what years, and how far into the future damages can be recovered, will we really be able to
20 accurately or finally determine total damages in all these cases.

D. Estimated (during fall 2016) approximate damages from most of the major damage
21
categories directly attributable to Gans RICO Enterprises Racketeering crimes ONLY,
22
including their improperly perpetuated coverups since 2013, which increased and multiplied
23
Remingtons time expenditures, related environmental and expert costs, lost Burl Tree profits
24
48
25 Normally under a continuing nuisance/trespass action damages would be recoverable for the
prior three years, however in this influential case, with other following courts, damages can extend
26 up to and through trial and final appellate verdicts. That is only fair in a case such as this one
27 which began in 2008 and still has not been to a trial nine years later, with constantly accumulating
major damages accruing every year. As per Spaulding v. Cameron (CA SC) it really is unfair to ask
28 a plaintiff to have to keep suing repeatedly and individually every three years, when a much more
just equitable and reasonable solution was issued by the RENZ court, which essentially states that
all recoverable damages may be recovered in only one jury verdict, as above.
665
and expenses, roughly directly proportional to the enterprises attempts to cover-up their
1
continuing crimes:
2
3 1. Lost iron sales attributable to the Figas extortions: At least $28,000
4 2. Overall lost profits due to the Wayne Marsh extortions: $18,000+
5 3. Defendants orchestrated vandalism of Remingtons fences, FELONY: $94,000
6 leading to garden foliage damage and killed roses and trees: Misdemeanor: $53,000
7 4. Increased homeowners insurance premiums: About $9000, to date.
8 5. Increased environmental experts costs: $25,000, and continuing
9 6. Legal fees, is projected going forward: Potentially $50,000
10 7. Lower slide damages, below dumps since 2012: $6000 and increasing annually
11 8. Upper slide damages, attributable to Randall, Figas and Marsh extortions: $22,000
12 9. OTHER Property destruction, thefts, equipment vandalisms (windows, tanks
13 irrigation systems, vehicles, etc., attributable to Mathson and his gang of hoodlums: $15,000
14 10. Additional Remington paralegal time and costs, $25/hour x 2000: $50,000
15 11. Increased administrative costs, supplies, printers, computers, remote storage: $17,000
16 12. Greatly enhanced security measures of all types as previously outlined: $9000
17 13. Lost ANNUAL water sales from Remington Creek (3 years), if captured and pumped
18 for $50,000 and delivered to Garberville-Redway, CA for drinking and irrigation: 3 X $400,000
19 Those damages alone, which increase noticeably every month, were caused directly by Gans
20 deliberate, prolonged and criminalized defense tactics approximately 2011, but herein we only seek
21 recovery under RICO for the past four (4) years. These damages were last estimated during
22 November 2016, and as predicted in the previous sentence have all increased, and none appear to
23 have decreased.
17. List the damages sustained by reason of the violation of section 1962,
24
indicating the amount for which each defendant allegedly is liable.
25
#15 & #16 above list most of the major types and categories of damages which
26
Remington herein alleges were directly and objectively CAUSED BY, or otherwise
27
attributable to defendant 1962 (c) & (d) violations, as opposed to the dozen or more cited
28

666
environmental statute violations, explained in the federal complaint itself. Those
1
environmental contamination violations are different and distinct from these RICO damages.
2
It is possible that some categories may have been inadvertently omitted at this early stage
3
of the complaint process in fall 2016, and in any event new categories of damages and new
4
damages within existing categories, occur frequently. They always seem to increase and never
5
decrease. At the proper time, as time permits and in any event when the FAC is filed in this case,
6
and when the first amendment of this RICO Statement is redrafted, these damages will be
7 augmented and amended.
8 Remington also reserves the right to amend them further, and as radically as All of the new
9 discovered facts require, before or during the trial of this RICO action.
10 Only actual and provable RICO predicate act violations are subject to possible treble damages
11 and Remington has herein made a preliminary attempt to sort-out RICO damages from the ordinary
12 garden-variety environmental statutory damages listed at the end of the complaint itself.
13 Without further discovery, attributing exact dollars of damages to individual defendants and
their helpers is rather arbitrary, subjective and a value judgment, where Remington, and each
14
judge or juror would reasonably differ, as would each defendant and their attorneys. Nevertheless,
15
Remington attempts to estimate exactly that on the next page, so that the court can understand
16
exactly how Remington at least views this case at this time.
17
At a trial, which results in a positive verdict for Remington and against this criminal RICO
18 enterprise, assessing individual monetary or other punishments to individual defendants would
19 become more important than it is today. At that time, written into special jury instructions would
20 be formally organized carefully drafted criteria intended to make as objective judgments as
21 possible regarding quite subjective monetary and punitive standards and judgments. At the proper
22 time, a judge who is experienced in these matters would need to properly and fully instruct a jury
23 taking into consideration the ideas and suggestions of the litigants. Obvious as that would appear,
that did not occur properly in the 2016 SOL state trial, and said jury was grossly under-instructed,
24
misled and legally confused, and Remingtons opinion.
25
Today, before this RICO statement is even required, Remington will do a less rigorous
26
estimate and approximate assessment of blame to individual defendants, based on the present facts
27
and his present understanding of the law, but which estimates and dollar values are expected to
28

667
drastically change49 when Kluck and Olson become actually active here, or after Mathson or Skillings
1
perform one or more acts of successful violence or attempted bodily harm against Remington or his
2
witnesses.
3
For example, anyone killing, maiming or attempting same on Remington physically would
4
immediately jump to number two on this listing below.
5 In January 2017, Remington makes the following additional rough assumptions, and adds up
6 some of the November 2016 subtotals, by way of example, to indicate to the court and defendants
7 the order of magnitude of Remingtons present RICO damages, which, as above, increase daily.
8 Given the following possible positive jury verdicts in favor of Remington, how should those
9 dollar damages be assessed to and paid for by individual defendants, and Remingtons
10 present opinion?
A. Assumptions:
11
1. Assume that $850,000 was recovered in the main complaint for nuisance, trespass,
12
general, special, punitive damages and all other miscellaneous costs of suit, which would
13
probably cover remediation expenses, indemnification, other reimbursable costs and physical injuries
14
(for Severe loss of labyrinth equilibrium, Profound hearing loss in Remingtons right ear, the very
15 serious Traumas accompanying Remingtons hospitalization and for other bouts of serious
16 pneumonia, etc, which required about six weeks of non-hospitalized treatments, each);
17 2. Further assume that $1.6 million in total RICO judgment dollars, attributable only to
18 RICO crimes, is recovered by Remington after factoring in treble damages;
19 3. Regarding the initial $850,000, the environmental defendants of The Mathsons, Gans and
20 Allied insurance would appear to be responsible for approximately $450,000 of that sum; whereas,
the RAO, Olson, Skillings, Kluck and their insurers portion of an $850,000 judgment would
21
therefore be approximately $400,000, at least. That is what Remington would judge today, and that
22
could be backed up with a 50-page additional analysis which is omitted here but includes the
23
immense costs and difficulties Remington has been subjected to from the Mathson-Gans faction
24
since 2006, but also factors-in the enormous illegal and unjust profits which Olson, Skillings and
25
49
The last time Remington used actual numerical dollar estimates was during October 2016, which numbers used
26 herein are merely exemplary of. Remington has made actual dollar estimates repeatedly in jury instructions before
trials and in several amended complaints, including this main federal complaint. No one has ever seemed to take
27 those estimates seriously, and since they are constantly revised and will be again before or after any trial in these
matters and especially after a RENZ decision, Remington declines to revisit all the raw data and estimates today.
28 Probably Remington suggest put down around number and millions of dollars or leave it entirely up to the court or
jury, according to proofs, however that is not Remingtons way and he prefers to provide objective subtotals which
when corrected or adjusted at some point, by a judge or jury, would lead to a valid recoverable total dollar amount.
668
RAO are known to have recovered, in the low to mid-seven-figure range. During discovery, and
1
when and after Kluck, Olson, Skillings and their insurer become actually active here in defending this
2
case, and thereby join Gans RICO racket as expected, these above numbers are going to change
3
dramatically, but how remains to be seen.
4
The RAO defendants should be forced to disgorge most if not all of their unjust profits, which
5 request is very specifically and emphatically made in DR140426 at Judge Reinholtsens 2015
6 recommendation under RESTITUTION. If this environmental case goes to trial prior to DR140426
7 which is reasonably likely, Remington would then emphasize the restitution count from the state
8 cases, HERE.
9 4. Further, regarding WHO should pay Remington a $1.6 million dollar judgment, before
10 they pay their fines and serve their time? In late 2016, Remington viewed that approximately
as follows:
11
A. Gans personally: $700,000;
12
B. Linda Lawrence personally50: $150,000;
13
C. John Mathson: $300,000;
14
D. Olson and/or RAO: $200,000;
15 E. Skillings: $50,000;
16 F. Plotz and Brisso: $100,000 (Plotz: $80,000, Brisso $20,000);
17 G. Other named defendants, and close associates, including McBride, Randall, Nelson,
18 Kishpaugh, Costa, etc: About $100-200,000 between them, perhaps reducing Gans culpability by
19 potentially $100,000 if the facts so indicate that most of these scheming co-conspirators and perjurers
20 did so willingly and enthusiastically. Kluck, RAOs insurer and even Skillings culpability and
financial responsibility are now not fully determinable, and if Skillings were to kill or seriously injure
21
Remington that would very literally change everything in all of these cases51,, as indicated above.
22
On the other hand, if a RICO judgment happened to be $1 million higher, then Remington
23 50
Arguably, and increasingly apparent into April 2017, perhaps Lawrences culpability above should be
24 at least tripled right now based on pre-discovery conceptualization. Also, McBride could have a gigantic
influence on Gans, may have egged-him-on and motivated him to the point where it is easy to conceive
25 that McBride plus Lawrence might be liable for as much as 50-80% of whatever guilt Gans is assigned by
a jury. Clearly, substantial discovery is now needed on both of those women, plus Joy Mathson and Olson.
26 51
Murder and many of the possible brutal racketeering acts that someone such as Mathson or Skillings might
undertake are generally not federal predicate acts under civil RICO, which one might intuitively infer would lead to
27 a much higher monetary recovery here. Therefore, even if Gans orders his fellow RICO defendants to do their worst
and get rid of Remington and this entire case the easy way, that would not necessarily lead to increase monetary
28 recovery for Remingtons heirs or the lawyers which would finish this off. In other words, a lot that is BAD can
happen in the next several years, and presumably plenty of that will occur, so final damages and who owes what
percentage of those damages is obviously very premature today.
669
would assign Gans about another $700,000 from that second or third million, and add similarly
1
proportionate much lesser amounts to the others named herein. In other words, Gans is arguably, at
2
this time at least as guilty as all the rest of the enterprise members put together. If a RICO judgment
3
was doubled, then Gans would be reasonably judged by Remington, to be twice as responsible and
4
culpable as all the rest of the enterprise members put together. Finally, on a billion-dollar
5 judgment, Remington would judge Gans culpability as being about 90% of the total judgment, and
6 the rest no more than 10%, at least based on facts known today. However, see March footnote
7 number 50 above for possible massive possible redistributions of blame after a few more years of
8 discovery into some of the substantially unknown figures in the RICO enterprise, especially the
9 three women named above. Women, today deserve equal treatment with men, and heretofore
10 they have somewhat slipped-under the radar, but are known to be extremely prominently
influential here.
11
Why is, or was, Gans assigned 90% total responsibility, at least prior to exhaustive
12
discovery on the above women plus Plotz, Brisso and a few others? Simply put, without Gans
13
there never would have been any RICO enterprise in the first place, and quite possibly many
14
present members have tried to discourage him and revert back to a legitimate defensive advocacy
15 here. If facts of that nature are discovered, obviously that will also drastically change the above
16 estimated and projected culpability assignments above.
17 Arguably, Gans is 100% responsible for Remingtons RICO damages; however, in view of
18 the extreme cooperation and very enthusiastic, zealous assistance Gans received from many of the
19 RICO racketeering members, Most especially from Lawrence, Plotz, Brisso and both Mathsons,
20 as specified above in perhaps excessive detail, there is obviously plenty of guilt and financial
responsibility to distribute, as above.
21
Just saying, and projecting based on present information. Thats what Remington would
22
proclaim today if he were judging this case after a large positive verdict, taking several more years.
23
However, a few years from now the discovered facts, evidence and anticipated additional serious
24
federal predicate acts will be very different and blame, and resulting punishments, such as fines,
25 imprisonment or the financial responsibility to reimburse Remington specific monetary
26 damages, would therefore, accordingly, be assigned very differently, by a trier of fact.
27 18. List all other federal causes of action, if any, and provide the relevant statute numbers.
28 The accompanying federal environmental complaint answers this question in great detail, with
all statute numbers. For the simple and most concise answer, see the cover of said federal complaint.
670
19. List all pendant state claims, if any.
1
2 Again, see accompanying federal complaint for a wide variety of pendant state claims which
3 includes some, but not all of the pending state claims in Remingtons two open state continuing
nuisance/ trespass successive action lawsuits, DR080678 and DR140426. For now, said
4
contamination portion of this federal complaint adequately summarizes the salient Remington
5
pendant state claims, and if any are missing or incomplete as presented in the State Court,
6
Remington will duly note that with appropriate revisions in his FAC.
7
Both of those state cases are now in limbo with no apparent qualified or available judge to
8 expedite or to even oversee both of said cases. That may have somewhat changed by April 2017,
9 however Remington is never received anything during 2017 from Judge Wilson who is at least
10 inferred to be now handling DR 140426, whereas Judge Reinholtsen now has DR 080678, under
11 advisement for some kind of decision as to what the next step is and Remington strongly anticipates
12 the worst and that he intends to quick-kick the case to the appellate court next, for serious study
13 and guidance of the obvious case law which governs it, which he does not seem to have the time or
the predilection to properly understand and apply. Remington has or will be requesting that both of
14
Said above named state cases be stayed pending results in this action, however what exactly occurs
15
with three cases up in the air, and which case falls to the ground first or takes Positive hold
16
somewhere, and actually proceeds towards or to resolution, is presently unknown. All that is known
17
for sure is that the enterprise will strongly oppose any of these federal cases going forward even for a
18 week, if they even decide to answer this complaint at all, let alone until a federal dismissal hearing
19 or beyond.
20 Gans and his RICO enterprise of course with their unlimited resources will vehemently
21 SUPER-oppose this action, in particular because they have at least one state judge very inferentially
22 under their influence, plus at least one crooked Humboldt County Superior Court state file room
23 saboteur to also further their criminal objectives.
In other words, Gans racketeering enterprise will desperately oppose this action like it was
24
World War III and IV combined! Thats fine, because Remington has nothing but time to oppose them
25
nowadays, with everything else in his life totally on hold, and still functioning. Remington is still
26
sleeping fine and eating great, and now even getting enough exercise to stay healthy.
27
Those two extremely powerful, valuable factors or weapons alone will cause Gans to argue
28 almost to the death to shut this federal action down, including this viable RICO cause of action. If,
however, Gans should somehow by subterfuge, trickery, legal technicalities and/or

671
mischaracterizations, be successful here, then Remington will immediately, as promised add a
1
California state RICO cause of action52 to his present two state actions, probably as a TAC or higher
2
amended complaint.
3
20. Provide any additional information you feel would be helpful to the court in
4
assessing your RICO claim.
5
A. Gans lies ALOT. That is the most important observation or warning
6
Remington can make to this court. He lies about anything and everything, he lies very
7
convincingly and unless he is specifically put under oath orally or in writing, the only
8
thing the court can be certain about is that some significant portion of what he
9
communicates will be false, entirely unsustainable and totally without merit.
10
Conversely, if he is just put under oath for anything or everything, he will then
11
say or write very little, and generally speaking, he will not lie in writing if proof of
12
those lies exists, which it almost always does, and additionally Gans knows that
13
Remington knows that he is lying and can also prove it with evidence, which makes
14
him super-careful when he rarely does find himself under oath.
15
To put it even more bluntly, if this court requires every statement in every writing
16
17 52
As soon as this case is filed and served Remington intends to enlist the assistance of local or federal
criminal authorities to prosecute these crimes under the numerous above-cited RICO predicate act statutes
18 and in the event that it becomes necessary under California state criminal codes including PC 186.2, 186.3
and also under B & P 17,200, etc when these RICO causes are added to the state claims at the time of the
19 next amended complaints. Perhaps adding California RICO to the state cases will be unnecessary if this court
20 fully adjudicates all issues, but if not and if Remingtons present RICO causes of action or surprisingly
dismissed here, then they will all be pursued energetically in the state courts under the appropriate violated
21 statutes including extortion, mail fraud and the numerous collusive conspiracies alleged in this federal RICO
action. Enormous illegal financial profits have been gained here by all named defendants since 1998, and
22 since 2012 Said huge unlawful and unjust profits have been concentrated into Gans RICO enterprise, as
more than amply explained. It is very possible that the FBI or the County district attorney are not going to
23 want to be bothered with Remingtons little insignificant nuisance action against their greatly feared,
possibly respected mentor and controller of Eurekas entire legal hierarchy, whose name is Brisso. Fear of
24 Brisso is justified because he inferentially has at least one primary Superior Court judge in his pocket plus
25 the other suspected and identified court staff, which all seems to be right out of the Godfather film, only
this story is true. In any case, irrespective of what happens here, Remington will still persist for the duration
26 and eventually prevail in the state courts, it just may take about 10 years longer there. In other words,
Remington can and will continue to prosecute this RICO case, somewhere, especially since it is based upon
27 contamination allegations, as a bona fide and lawfully permitted and described Private Attorney General,
as perhaps first described by Justice Souter in Rotella v. Wood, 528 US 549, 558 (2000), citing to Agency v.
28 Malley-Duff, 483 US 143, 151. As such, and also under other authorities such as Dasher v. Housing, 604 F.
R.D. 720, Remington may appear Ex relatione, either on the part of the people of the United States or of
California.
672
1 from Gans to be sworn to under penalty of perjury, since he cannot exist in the
2
truthful world, he would therefore be guaranteed to drop all his defenses, and these
cases would therefore have to end almost instantly.
3
All that would be required to reach that outcome would be for this court to
4
merely look him directly in the eye during the hearings, and force him to be truthful
5
about anything, let alone everything! All that really means, is that Gans should be put
6
under oath before he is allowed to open his mouth in this federal court in any hearing
7
and about any subject. He especially, and attorneys in general feign humiliation at
8
or supremely beyond being subjected to that concept, however Remington assures the
9
court that in this case it is necessary, absolutely.
10
Therefore, in that additional regard Remington would add the obvious: Do not take
11
anything that Gans says at face value. Demand proofs and evidentiary examples of anything that he
12
states as being a fact. Hold Remington to the same standard, please.
13
Assume that Gans significant and substantive case citations are partially or often mostly off-
14 point, assume that his histories and backgrounds are jaded, fallacious and mostly just FALSE, and
15 watch for his extensive use of and total reliance upon false logic and overall unethical advocacy
16 methods.
17 Additionally, any time Gans or Plotz use the phrases obviously, it is self-evident or
18 similar, that means that they have no evidence at all for the statement; it is likely false or absolutely,
19 at a minimum, a material mischaracterization; or it is an introduction to a false syllogism which
may appear to be likely or possible, but with that sort of a preface it is 95% probable that it is just
20
false or a lie. Much of defendants unverified motion documents contain significant amounts of
21
false statements, fake facts, grossly mischaracterized versions of the case history and the actions
22
or motivations of the parties, or worse. That is why Remington often and routinely puts his
23
motion documents under penalty of perjury, either directly or as rewritten in a Declaration of
24 Bruce Remington, in order to provide some sort of a contrast to a disingenuous attorneys motion
25 document. Virtually anything that Remington writes can always be sworn to, unless it is complete
26 conjecture, which would be highly unusual nor can Remington recall a single example of such.
27 Remington also stands behind all of his adjectives and non-lawyerly sounding
28 characterizations, which are all 100% strictly based on his own personal experiences with Gans and
the RICO enterprise, and his good recall thereof.
673
Obviously, a pro per is at an enormous disadvantage to a reputable assumed ethical (by
1
default) licensed California attorney as far as credibility and initial assumed veracity are concerned.
2
Here, that disadvantage should be considered and weighed where one party is always and
3
continuously willing to swear to his version of the facts and the other literally NEVER IS. Gans is
4
only willing to swear to perhaps 1 in 1000 of his scores of mostly inaccurate or grossly
5 mischaracterized declarative statements in his motion documents. Said documents are also riddled
6 with case citations which whenever they do apply to a substantive matter at issue, reading them as
7 Remington always does, shows that rarely do defendants ever properly present most decisions in a
8 balanced manner, and they always completely omit any teaching, as though it were not in the case,
9 which would conceivably benefit Remington in any manner, which one-sided presentations are
10 improper and inappropriate for a California attorney.
Related to that point is that Gans and Plotz actually rarely lie or perjure themselves in their
11
written declarations, but therefore it is extremely rare for them to swear to anything of any
12
consequence or factual significance in a declaration. They know that Remington is warily watching
13
their every sworn statement for perjury, mischaracterizations and related false facts, and
14
consequently they rarely provide such under oath, after being seriously burned several times,
15 mostly in 2011 before they became more careful in their sworn declarations.
16 B. Eventual disbarment. Remington has probably written more than 300 FILED State and
17 federal court motion pages on similar and related topics, especially backing-up his CCP 128.7
18 motions, from a few years back. Although not necessarily relevant here today, at some point
19 assuming that it is relevant and that the court is at all interested, Remington will probably file a new
20 128.7 motion in this court based on 2011-13 unethical and worse litigatory acts by Gans in that
time frame, and also since then as generally alleged herein. Some of that was previously sent to the
21
magistrate court in Arcata, CA during about January 2016, but was returned with a note that they do
22
not issue advisory opinions. Subsequently, the idea for this entire lawsuit percolated and
23
developed into what is filed in accordance with this statement.
24
In other words, there is a very long unethical written and oral record made by Gans, especially
25 in these lawsuits over the last 10 years, in both state and federal court. Remingtons prior 128.7
26 motion in state court was heard by Judge Watson, and it relied heavily on 45 very unethical, false
27 and unacceptable lies and other misrepresentations made by Gans in federal court. Judge Watson
28 commented on that and said that Remingtons motion would be more appropriate in federal court
and was therefore Denied, at this time. Remington believes that he made a viable ethics claim
674
then, but in the wrong court and next time hell do it differently and better. This lawsuit is
1
something of an attempt to refile that 128.7 motion, only on steroids, now that we fully appreciate
2
what has been going-on for years here, but now it has become exponentially worse recently
3
Meanwhile, inferentially the present state authorities are not going to do anything about Gans
4
rather obvious ethical failings and violations, until some knowledgeable California judge first backs
5 Remington up on his allegations, which are further asserted and repeated here in this RICO action.
6 C. There are 3-4 or more judges here that know Gans and Brisso are crooks, in
7 essence, so they have all disqualified themselves, based-on 170.1, which includes Cissna (twice,
8 including once very recently) and Judge Miles, plus others, including virtually all of the most
9 ethical and best qualified Northcoast courts.
10 Judge Reinholtsen would have been the obvious court to challenge Gans ethics, but as alleged
above, with great disappointment, said court is not only reticent to do so, and not only blatantly
11
ignores all of Gans ethical violations; but, as alleged, he seems to go even somewhat beyond that.
12
Oddly, Judge Reinholtsen, in effect strangely protects Gans and then almost seems to hold
13
Gans ethical failings and false mischaracterize facts against Remington in a prejudicial manner,
14
such that Remington has been forced to shut-up about ethics violations in a court where ethics
15 obviously do not reign supreme. In other words, like a mirror, Remingtons accusations of Gans
16 dishonesty were very unjustly and wrongfully, but clearly, reflected back on himself in Judge
17 Reinholtsens court, by said judge himself as if he held-up a mirror in his hands. Therefore, as
18 explained above, said Judge now gets angry if Remington accuses Gans of any impropriety, LIE
19 or other disingenuous suborning of perjury or any sort of criminal act, of the plentiful quantity to
20 choose among. Gans crimes, transgressions, inaccuracies and lies come up often, but the court
always acts as though Remington is accusing a former law partner whom the court now needs to
21
protect.
22
D. No more information is presently needed here today to present a viable RICO case,
23
but plenty more is available and will be gathered in the future from both discovery and further
24
review of the approximately 50,000+ pages in these underlying litigations, where most pages have
25 one or more ethical transgressions and related problems under discussion, and every re-reading of
26 the old motion documents from 2012-16 usually causes a re-thinking of and often and adding
27 to those predicate acts, once the RICO law has been fully understood as it mostly is now.
28 Over the past nine years, Remington has learned to accept and acquiesce to very unethical and
sometimes illegal conduct as the default behavior from defendants attorneys.
675
Perhaps surprisingly, Remington is actually just too nice a guy here and is obviously not
1
nasty and combative enough to properly confront Gans activities, nor did he always know exactly
2
how to do it. Remington was a semi-retired, calm and peaceful nearly full-time gardener for several
3
years before these lawsuits first developed, and he never has been quite angry, mean and
4
ruthless enough to deal with either Gans or Mathsons continuous criminal destructions,
5 alleged above.
6 Nothing much as changed today, except Remington is now getting impatient with all this and
7 is going to make every effort now to fully enlist a local qualified trial attorney to help him in future
8 trials, and also has begun during April 2017 working strenuously, diligently and forcefully with the
9 local criminal authorities to investigate the scores of crimes involved here and especially to locate
10 all the sources of RAOs illegally dumped materials from 1998.
In other words, Remington acquiesced to numerous unethical and criminal acts in these cases
11
for many years without much complaint. Remington just stoically endured it, repaired the damages
12
when he was down in the appropriate areas and did a lot of complaining and declarations and
13
motion documents, but did not do enough work with the criminal authorities early enough. Nor did
14
he buy his numerous surveillance video cameras soon enough, otherwise John Mathson would be
15 still in state prison Remington had always been used to 10 times greater pressures, problems and
16 even thefts while he was in a very dangerous and aggressive businesses, where he had a largely
17 unprotected several hundred thousand dollar burl inventory exposed to thousands of criminal burl
18 thieves who had little trouble climbing cutting 8-foot chain-link fences at his outdoor sale yards
19 from Myers Flat to Crescent City. Guard dogs were used some places and were effective where they
20 were used, but they bring numerous additional problems along with them which are beyond the
scope here, including Remingtons wife objecting to their inhumane treatment at our remote
21
stores. Therefore, Remington did not really respond with enough intensity, focus, determination or
22
high enough intellect, soon enough in these lawsuits,.
23
He also never got the expected cooperation from Judge Reinholtsen which would have been
24
invaluable. Said judge was always very friendly and kind to Remington, but in retrospect he was
25 maybe too kind, too helpful and obsequious and perhaps, in retrospect, almost apologetic and kind
26 of sympathetic for his lack of motivation, perhaps lack of ability, probable implacable bias from
27 June 2016 forward, or other unknown but inferred factors, causing him to NOT deal with, and to
28 loudly ignore Gans long-time unethical actions, which have now fully morphed into alleged
fully-illegal behavior, as described.
676
Remington has considered that the Mitchell firm has either extorted or otherwise unduly
1
influenced Judge Reinholtsen since June 2016, as alleged in several motion documents, including
2
several related 170.1-6 motions and herein; Therefore, Remington is now looking for evidentiary
3
support or rebuttal of that inference, but has not yet discovered anything directly relevant, either
4
way. Supporting or exculpatory evidence will now be sought aggressively over the next several
5 years, about that and about a thousand other relevant facts alluded to or pertinent to the crimes
6 alleged herein. But, proving that a judge is unethical, biased or has been bribed is obviously beyond
7 difficult to prove without a direct confession, or some knowledgeable witness coming forward
8 honestly with at least some kind of rumor, even if they saw no money changed hands. The
9 conferences were clear, Remington properly presented them in various 170 motions, but a distant
10 Sonoma County judge who did not know Remington and may not have known Judge Reinholtsen
either, made a ruling on the evidence which we had and found that it was insufficient to legally
11
disqualify the judge. Remington cited influential cases that in some federal courts its automatic that
12
a former law partner cannot preside over a subsequent case involving that law partner, but here in
13
California that is not an automatic disqualifier.
14
E. OTHER relevant information added in February 2017 at the end here to avoid having to
15 repaginate, totally REFORMAT, and index these documents, plus this document CRASHES much
16 too frequently during editing due apparently to its length, complexity, programming within Libre,
17 which is in itself far-superior to Word 2011, plus some associated other programs which Remington
18 uses, an overall any long skips of 80-200 pages at once apparently overloads the memory causing
19 crashes which can be seriously detrimental it saves are not done 5-10 times per page.
20 1. On chasing dangerous animals out of Remingtons gardens. Is that just some frivolous
imaginary paranoid complaint by the 75-year-old Remington, or is there some validity to it being
21
part of defendants extortion objectives? This topic was covered extensively above, but additionally:
22
A. During this lawsuit around 2012-15 Remington became gravely ill three different
23
times as a result of exposure to toxins in the dump, both airborne and inferentially waterborne
24
bacteria associated with viruses. Some of those illnesses have been recounted in detail in the state
25 litigation and alluded to in the federal environmental complaint, so for this document, suffice to say
26 that Remington contracted pneumonia twice, one serious flu which developed into a pneumonia,
27 various related and apparently associated and contributory upper-respiratory illnesses presumably
28 from Mathsons airborne asbestos and other toxins which contributed to the above. At one point in a
known week of January 2015, the above respiratory and an E. coli-coliform-like debilitating
677
disturbances described, causally noticed to develop directly after and from contact with various
1
Mathson contaminated waters below the dump, developed into a shingles-like illness. It developed
2
rather slowly over several weeks and one day it became catastrophically acute and Remington could
3
not move or leave his bed at all and had to be carried out of his bedroom to an ambulance and to the
4
hospital. Approximately simultaneously, severe labyrinthitis and Ramsey Hunt syndrome
5 developed, leading to an eight-day hospitalization, which did not lead to any improvement, but
6 produced something like an $80,000 bill, and various serious permanent disabilities, as a result.
7 Those disabilities which are relevant to this point are a grave loss of equilibrium and
8 labyrinthitis caused by the 90% hearing loss in one ear, -20% hearing in the other and also some
9 deleterious impact on the right eye, which still exists but fortunately the eye itself was not lost or
10 the vision damaged. Many other symptoms remain today, including tinnitus, venous stasis, various
types of nerve pain and severe scalp itching, which are among the remaining obnoxious symptoms
11
of Postherpetic Neuralgia, persisting now two years later, with constant pain and itching which
12
requires treatment, and a variety of medications still. The severity of the various attacks attributed
13
to the contaminated dump conditions now continue to involve a 30% increase in stroke risk, where
14
the above-described pathogenic attacks involved the edge of one eye, plus increased risk for
15 hypertension, coronary artery disease, diabetes, heart failure, weight increase and renal disease.
16 Relevant here however, and caused by the above litany of suddenly appearing physical
17 ailments after Remingtons previous hundred percent very strong and healthy life, is that chasing
18 deer off a steep mountain slope, which is just like rapidly going-up and down the stairs of a 25-
19 story building is now onerous and extremely dangerous, because Remington stability is greatly
20 impaired and he cant move that rapidly anymore or stay balanced on the slippery paths, or
wobbling redwood rounds, without falling frequently and tripping over objects, especially in lower
21
light, near dusk. Naturally, dusk is when virtually all deer are first discovered, after they sleep in
22
dense brushy areas during the daytime, and consequently it is usually after dark when holes must be
23
located, and then fences must be mended, with whatever branches and wire happens to be at hand
24
by flashlight. In other words, defendants letting deer and bear in here 2-3 times per week is actually
25 a serious problem for Remington, which defendants well-know. All it takes is one moderate to
26 severe fall, somewhere down the mountain at twilight, and Remington would no longer be able to
27 crawl out of there, or be found or really missed, in any helpful or meaningful way were any kind of
28 search could be or would be initiated, until perhaps 24 hours later. If Remingtons wife woke up at
6-7 AM and Remingtons car was not in the driveway, that would usually be the first time that some
678
kind of search might be initiated, and after a night laying in 40 storms or 35 sleet, there probably
1
would not be much left to rescue.
2
B. The physically destructive damage done by said wild animals on the Burl Tree
3
property has been well-described in these documents, as has the huge extortive value to
4
defendants on Remingtons entire family been described. Remington has also attempted to place a
5 dollar value above, upon the RICO enterprises damage to Remingtons rare plants, such as said
6 deer have eaten-up all but about $500 worth of the originally $12,000 of flowering BULBS
7 Remington planted here in the early 2000s.
8 Also mentioned, but not emphasized was the fear and extortion which defendants have
9 implanted now in all of Remingtons family and especially in his three very young grandchildren,
10 who understandably and correctly are afraid of large bears lurking around in the rose beds with their
cubs, or also the danger of medium to large deer, especially those with antlers that become trapped
11
or startled near dusk and run blindly away trying to escape at up to 30 mph, nearly impaling
12
Remington on one occasion. Remingtons wife is also entirely given up ever visiting this property
13
and there are also many other potentially dangerous animal species recorded on video in this area
14
which also run rampant here after the impenetrable fences are cut, and include coons, possums,
15 skunks, large foxes in packs and also large dogs, usually running wild in groups of 2-3.
16 C. In other words, Mathson and Kishpaugh, under Gans tight control, are essentially
17 psychotic maniacs who observe Remington carefully with binoculars all day long in daylight,
18 know what works, see Remington is having difficulty maintaining his fencing and lower gardening,
19 and take advantage of that accordingly, in order to drive Remington to desperation and make him
20 leave these properties, in accordance with the RICO enterprises objectives. Other soldiers are also
involved in the above destructive acts, which have not been all identified from only their legs or
21
torsos in some cases, except for Gans of course shows up full-bodied in many videos.
22
The above problems and issues may not seem that important or significant to a court sitting in
23
a major metropolitan area, but Remington assures it that the above described extortion by wild
24
animal of an old man trying to protect 2-7-year-old granddaughters on a steep remote garden
25 slope, although possibly not yet in the Supreme Court precedents, eventually will be and is just as
26 serious a problem as many other non-bloody complaints that litigants have. It just is somewhat hard
27 to communicate without too much hyperbole, or without a grandkid or grandpa actually being
28 injured or killed.

679
D. ANALOGIES for this court: Suppose Gans and Mathson let loose four black bears,
1
including a mother and her three cubs, in the twilight and darkening corridors of this San
2
Francisco courthouse to run around in a panic, looking for food and a way out. Running-around
3
there is no different in danger and anxiety than running-around here. If one attempts to properly
4
appreciate that circumstance and possibility, there might be some chance that this court or other
5 readers could understand what Gans and his enterprise members have well-understood for about
6 eight years now, about conducting a terrorist and extortive campaign against Remington, and have
7 deliberately and brilliantly applied, executed and enhanced that campaign, under Gans charismatic
8 and energetic leadership, since about 2012.
9 E. Analogy number two. During the daytime, what is more important to a district or
10 appellate federal judge than mental focus and concentration in their endless difficult reading,
comprehension of complex detail in totally unfamiliar disciplines, and their continuous multi-
11
houred study sessions while attempting to understanding abstract case issues in terms of
12
specific laws, from invariably badly-written legal documents, written by idiots with either too
13
little or too much detail, and usually no photographs?
14
Suppose the above analogy was altered to involve 10 dogs running-around the corridors of
15 the courts office building during the day, barking at anyone that moved about? Or, how about three
16 young children racing, thundering and laughing down the judges hallways, how would that work,
17 almost every day, year after year?
18 Obviously, at some point the person controlling those disturbances, whether actually occurring
19 at a given hour, or whether they occur often enough that said judges our continuously wondering if
20 or when the disturbance will start up again, has actual real serious control over you and HERE
Gans and his enterprise understands and then intentionally perpetuates that control, almost daily. At
21
the courthouse, there are security gates and guards and plenty of employees to deal with these
22
issues, however suppose you are a one-man operation with no security gates or employees to deal
23
with these issues, such as Remington is in his secured offices and vast yard. Here, when or if the
24
police are called there is a too long and several our distracting wait, with nothing for them to see if
25 they ever do get here, because the animals are hidden, gone or have disappeared back through
26 Mathsons secret doors or holes, which holes if made in the middle or bottom of Remingtons
27 fences, as soon as they are discovered, they need to be immediately and urgently plugged-up to
28 prevent a dozen more deer per hour from entering, where each deer can potentially cause several
hundred dollars of rare plant damages in one night.
680
F. This is the point. Concentration and mental focus are absolutely crucial to a judge,
1
lawyer and believe it or not, concentration, peace of mind and clear mental focus is obviously
2
just as important, if not more so to an older, 75 year older, non-lawyer litigant who has to
3
research and learn each of these issues and read at least 10-20 of the correct conclusive cases daily,
4
understand them, and take notes on them, one by one as though he was 22-years old in law school.
5 There are those that think that method is a better way of learning to be a lawyer than actual law
6 school, especially 20-solid years of intelligent reading, with plenty of practical application and with
7 good retention, but thats another topic for another document.
8 Little else around here or THERE is more important than peace, quiet, with a proper
9 environment for continuous full and deep mental concentration, and many years ago Gans and
10 Mathson, et al figured that out, especially around major document deadlines, and so they have
impeded and obstructed Remingtons ability to work properly here, for years. As discussed above,
11
set-up a final deadline for a summary judgment opposition filing, and invariably since about 2011,
12
for the two prior days Gans makes sure its like a veritable zoo around here with noise,
13
snorting, blurred running motions, major property being destroyed while Remington works, which
14
also makes it somewhat hard to concentrate.
15 Think of it this way. That would be similar to a judge in San Francisco knowing and hearing
16 his fancy super-expensive, too valuable to be insured car being slowly destroyed by animals or
17 someone with a hammer, and then just having to ignore what it knew was going on outside, in order
18 to meet some deadline, which deadlines are probably less stringent to a federal judge than to a
19 litigant, especially one in Pro per. Pro pers have to worry about being thrown-out of court for any
20 minor technical transgression, no matter whose fault it was.
Anyway, that distracting activity described-above which Gans perpetrates upon Remington
21
very regularly at major deadlines or during the recent jury trial, which requires many hours of
22
sophisticated and clear preparation, to Remington, is no different than a pack of crazed animals
23
running around the corridors of the San Francisco courthouse. Remington believes that it is real
24
creative, actual damaging extortion, as explained above, that is serious to Remington and
25 therefore it is one of the issues in this litigation.
26 Defendants clearly intend to continue their extortive activities until all of their RICO
27 objectives have been reached, andUntil they have obtained most or all of Remingtons property
28 without any cost to themselves. Removing or stealing a judges or litigants ability to concentrate
on abstract complex legal issues is a true threat, and a legitimate damage, once it is properly
681
understood. It is a federal crime, and also directly causes business property damage because if
1
Remington cannot concentrate on his legal work, he cannot do any significant business activities
2
either. The case law clearly shows that extortion takes many forms and can be various types of
3
coercion, threat of physical harm to the person or family and also it can be merely causing the
4
stress of mind, which can include the fear of crime, Fear of suffering financial loss, Fear of
5 becoming so distracted and angry that no useful work of any kind can be accomplished, and the
6 realistic fear of vandalism, especially where those fears are properly and validly justified, by their
7 continuous and daily occurrences. Here, those occurrences are obviously well-known to defendants,
8 who were involved with Remington for three hours per morning in 2016 pretrial hearings, but who
9 always were able to easily make it known in various ways with their blatant, unbroken stares that
10 they are or were (in real time) causing Remington significant harm, torment and obviously loving it
and laughing about it quite indiscreetly. Remington being a rather observant, sensitive and
11
introspective man was able to watch Gans, Mathson and Plotz daily for effectively six (6)
12
consecutive months in Judge Reinholtsens department eight court room, while they very carefully
13
observed him several times each morning to see how how he was sleeping and specifically reacting
14
to their carefully orchestrated tortures on a given day, and also to evaluate whether he was feeling
15 the irritation, anxiety or real-time anger from their destructive forces, that they had just let-in to
16 Remingtons property that very morning, while Remington was away at his residence getting a
17 good nights sleep for the trial hearings.
18 Additionally, related to the above vandalisms and defendants RICO crimes, is that virtually
19 all of the major vandalisms occur from on Mathsons land and from doubly fenced-in areas, which
20 are well-patrolled by Mathsons gang of vicious, incessantly barking guard dogs, which only the
Mathsons and Kishpaughs have access to, and no one else on this earth. Therefore, when the fence
21
is broken or and attack comes from Mathsons double fenced in land, it does not take a brilliant
22
genius to deduce who did the crime, when John Mathson and some of his gang are the only people
23
on earth that would have the nerve or ability to break-down cut Remingtons fence in that area,
24
without risking getting shot and killed by Mathson or his men.
25 2. Additional discussion of and in anticipation of what Gans personal defense and
26 specific denials will be regarding his violations of federal RICO predicate acts.
27 As explained above with considerable particularity, like any thoughtful and cerebral white-
28 collar criminal, who thinks he is too smart to be caught, Russell Gans will deny all allegations
without swearing to anything and then blame Remington for all evil and problems in the world.
682
Knowing Gans all-too-well, MUCH too well, for a full 10 years now, there is absolutely no
1
doubt that he will claim that he is innocent of all of these charges, he is not a crook any more
2
than Nixon was, and in fact it is, believe it or not, actually Remington, himself that is a crook,
3
who made up all of these allegations because he had nothing else to do for the last six months.
4
It was obviously Remington who committed all of the unlawful acts here, Gans false premise
5 logic will begin, because he also had access to his own property, so obviously it was Remington
6 who deliberately destroyed his own gardens, windows and business property, more than $100,000
7 of rare plants which he personally hand-planted, laboriously nurtured, hand-carried in the mulch
8 and fertilizers for thousands of plants far-down the mountain on difficult trails, watered them by
9 hand-carried 5 gallon buckets in many cases, after he had done massive clearing and development
10 of the land in the first place, on literally as difficult and inhospitable terrain, as any beyond-rugged
land that was ever cleared any time and anywhere; all, just so that he could unjustly blame and try
11
to frame the poor nice Mathsons, who just want to mind their own business and end these
12
lawsuits, by any means necessary. Sure the Mathsons may have dumped a couple million pounds
13
of contaminated debris on Remingtons land, that they want to leave there forever, plus appropriate
14
and STEAL all that land, which debris was placed their on Remingtons land solely to support their
15 own major half acre expansion of their lawns and gardens on the mountaintop above, plus all of
16 Remingtons land directly below that 2 million pounds of hazardous contaminated debris, but so
17 what? In spite of all that, in Gans illogical and corrupt world, the polluting Mathsons are the
18 victims here clearly and not Remington!
19 More specifically, Gans numerous alleged predicate acts, at the summer 2016 SOL trial, for
20 example which included, without limitation: Obstruction of justice, multiple suborning of perjury,
witness tampering of witnesses from both sides, paying his fact witnesses excessive witness fees
21
which amounted to bribery,witness training, coaching and writing false declarations for them,
22
massive unlawful evidence spoliation, evidence suppression by corrupt disingenuous arguments
23
which were accepted by the court due to its improper influence, bribery [suspected possible
24
violation of 18 USC 201 (b) (1) (A), (B) & (C)] or simple trickery caused by misplaced trust and
25 confidence, and Gans multiple material misrepresentations, and multiple lies, mischaracterizations
26 and deceptions TO a state court judge, damaged Remington and the Burl Tree directly (as
27 below) because those actions cumulatively resulted in and solely CAUSED Gans and Mathsons
28 illicit total victory at the SOL trial. Defendants believe, have postulated and disingenuously
promulgated that now they must summarily win all of these cases. All of Remingtons cases must
683
be immediately dismissed, defendants now very knowingly falsely and deceitfully argue, which if
1
such dismissal does occur (from Judge Reinholtsen falling further under Gans and Brissos
2
wrongful spell), that additional collusive state or federal fraud would result in further actual cash
3
losses to Remington of at least $500,000-$1,200,000, according to proofs and current calculations
4
at the next trial.
5 It should be clarified here that all of the above predicate acts from the 2016 SOL trial and
6 many other individual acts of mail and wire fraud or attempted extortion may not be federal
7 predicate acts individually in themselves but must be looked at and read in combination with the
8 terms of the RICO enterprises objectives. Additionally, as repetitively explained, all state perjury
9 and unlawful acts will be necessarily repeated by Gans enterprise imminently in federal discovery,
10 which will promote them into being federal predicate acts.
For example, it is not a RICO predicate act for Gans or Brisso to willfully and believably
11
threaten Remington with a lawsuit for malicious prosecution, slander, abuse of process and punitive
12
damages, ETC, if Remington were to lose one of these lawsuits. Making those threats alone are
13
not an imprisonable offense, however taken in combination with all of the acts together they
14
are, especially when falsely sworn to during federal discovery. Reading and understanding the
15 allegations contained in the almost 700 pages herein, and analyzed in terms of the known RICO
16 enterprise objectives, it would appear to Remington that they are imprisonable offenses. This court
17 must determine that, however.
18 3. Remingtons civil rights were deprived under 42 USC 1983 in the several manners
19 described with particularity above, which were especially attributable to GansRICO purposes.
20 Remington alleges that he was deprived of either life, liberty and/or property without proper prior
notice and opportunity for hearing appropriate to the nature of the case. Until Remington actually
21
loses one of these cases he may not have suffered serious property loss, plus he still has a
22
meaningful post-deprivation remedy of a tort action in state court. This area will be more completely
23
analyzed in the future, and more deprivations are believed to exist than what have been presently
24
discovered and therefore alleged above in this RICO statement.
25 For example, Remington has alleged at length for years that the RICO enterprise has unduly
26 influenced and clearly bribed various Humboldt County Superior Court clerks to sabotage
27 Remingtons documents to result in his cases being dismissed. There is absolutely no doubt about
28 that fact, however we do not definitely know who the criminal perpetrators are yet, after several
internal investigations by courthouse managers.
684
Remington has postulated two possible names, above, based on his and the file room
1
managers previous at least three (3), since 2009, investigations of these crimes. Whether discovery
2
will implicate or vindicate those two names is unknown in February 2017, however at some point
3
Remington reserves the right to file suit based on those crimes and torts alone if relief is not attained
4
in this lawsuit, and if the County District Attorney and/or Brisso do not take an interest in this
5 prosecution, or allow it to meaningfully proceed. Remington has an important witness that claims
6 that there is no way the county is going to back Remington against Brisso in any aspect of these
7 cases, but that as yet remains to be clearly put on the sworn record. Additionally, Remington has
8 alleged that Gans has orchestrated continuously since 2008 and at least until 2017, a large variety of
9 approximately 40 different state and local government agencies to mount a major extortive,
10 harassing vendetta against Remington and the Burl Tree, which activities clearly violated the
established statutory or constitutional rights of Remington, and continue to do so in 2017. We will
11
attempt to associate and prosecute more of those violations in this case at the time of the FAC, if not
12
before, as they become further discovered, admitted to in various RICO action planned depositions,
13
better understood, and additionally researched, as time permits.
14
4. INSERT Y FROM (former) ABOUT PAGE 82 DISCUSSING GANS
15 UNETHICAL AND QUASI-ILLEGAL LITIGATORY BEHAVIOR SINCE ABOUT 2011,
16 when he gave-up all pretense of trying to win these cases by ordinary, ethical California civil
17 procedures, as he might be forced to employ against a fellow attorney with an independent judge
18 who was NOT a former law partner and confidant. Some of this is significant background related to
19 Gans integrity and hyper-aggressive litigation techniques, but much of this occurred during 2012
20 and since, when Gans is deposed in this federal case.
Miscellaneous Gans and Mitchell attorney transgressions, including without limitation:
21
multiple frauds, misrepresentations, numerous grossly mischaracterized issues, grave
22
inconsistencies in Gans legal positions, lies, fabrications, tricks and perjury, etc., in support of
23
Gans alleged RICO enterprises predicate acts, which are all consistent with Gans corrupt
24
conspiratorial intent and improper litigation practices dedicated to defeating Remington, primarily
25 with his unlawful actions.
26 1. Over many years, beginning in about 2009 and repeated as recently as 2014- 2016, both
27 Gans and Brisso have presented false and fraudulent requests for inflated numbers of hours at
28 fraudulently excessive lodestar attorney fees to Remington and several courts, and generally
double-billed and fabricated more than a majority of their costs, such as charging Remington for
685
filing fees in unrelated cases after being preliminarily granted the right to be reimbursed for
1
reasonable special motion costs. As a primary result of said frauds and state in Federal Court,
2
Remington now is being billed approximately $13,000 total by defendants, the majority of which
3
was obtained by fraud on the courts;
4
2. Russell Gans lied about meeting and conferring with Remington during June-August,
5 2011 prior to his protective order and summary judgment motions in federal court. Said meeting
6 and conferring is required under three different levels of federal law and regulations and when
7 Remington objected to that lack of notice or attempt to resolve the dispute without court
8 intervention, Gans simply lied about it in a declaration directed to Magistrate Vadas, District Court
9 Judge. That issue was raised by Remington in his Ninth Circuit appeal between 2012-2014 and
10 was never directly refuted by Gans, because he knows he cannot prove any meetings, because they
just did not occur. The Ninth Circuit was involved with the basic question of whether Magistrate
11
Vadas could summarily dismiss Remingtons entire case based on rule 37 (b), determined that it
12
could and therefore never reached any of Remingtons 100 other valid disputes, accusations and
13
injustices, many of which are contained in this listing;
14
3. Twin pipes frauds and perjuries. Gans corruptly, improperly and unethically failed to
15 correct his experts Ferriman and Gwinns perjury after they re-studied the infamous twin 6-inch
16 pipes on Mathsons land in 2012, during the federal briefing process. This issue was extensively
17 discussed during 2016 state pretrial hearings were Gans lied directly to Judge Reinholtsen, but said
18 judge was not worried about it and refused to order the simple few minutes of investigation which
19 would have resolved the issue and proved, once and for ALL, that Remington has been correct in
20 several hundred pages of sworn testimony on this critically important material subject and that
Gans, John Mathson and all of their experts have lied about it in every year these lawsuits have
21
been going on. Defendants know why this issue is important and it is somewhat beyond the scope
22
to write, or copy from numerous other documents, the 3-4 additional pages to explain it at this
23
point;
24
4. Gans expert Ferriman made a $10,000 remediation estimate and bid for removing their
25 encroaching, trespassing hazardous wastes from Remingtons land in about 2010, but then revoked
26 it for complex reasons, the most important of which was that it was a flagrant and obvious fraud
27 from the start and was merely a settlement ploy and also a blatant, outrageous and deceptive
28 fraudulent misrepresentation by a factor of about 20, at the time it was made;

686
5. Similarly, the Blue Rock water test in 2010 was also an intentional material fraud,
1
deliberately perpetrated upon Remington, his experts and several different courts by Gans,
2
Ferriman, John Mathson and Brian Gwinn, wherein they claim that said pipes were the perfect
3
test case for proving that Mathsons fill was pristine and uncontaminated because water filtering
4
down through it and into the pipes was drinkable.
5 Again, sparing several pages of detail, said pipes were (and still ARE) solid and not
6 perforated (as defendants have and continue to falsely swear), so water percolating down through
7 the fill just ran around and beneath the pipes, where that water is highly contaminated, but did not
8 get into the pipes themselves because said pipes were solid. Said solid hundred foot long pipes
9 originated in the middle of Mathsons mountaintop lawns where a pristine spring plus County
10 irrigation water is diverted down through the pipes to their termination point where said
defendants experts measured the water and proved essentially that County drinking water meets
11
those standards, but proved nothing whatsoever about the toxicity of the fill, is there fraud on the
12
court pretended. The county had that factual information in their reports as early as 2008 which
13
had been told to them by John Mathson who therefore lied in his GANS drafted 2008-10
14
declarations on the subject, knowingly passed along false information to Ferriman, County
15 investigators and many other experts, and in summary all of these RICO defendants involved with
16 this issue committed knowing perjury and fraud against Remington and all of the above. Further,
17 all of the above including Remington and his experts reasonably relied upon that information and
18 the integrity of Blue Rocks testing, for years and were damaged thereby;
19 6. Gans unethically subpoenaed Remingtons February 2011 SHN test results, which were
20 mostly incompetent and in any case were not going to be admitted as evidence. However, Gans
illicitly subpoenaed said tests, without a court order as required by law, merely by scaring and
21
extorting Northcoast Labs, and just threatening and ordering them to improperly produce said tests
22
or else, without getting permission from Remington or a court. Said easy-going Northcoast labs,
23
not wanting another lawsuit with the Mitchell firm, immediately surrendered the test results
24
without complaint and presumably Gans had assured someone there that they were required to
25 send them if he requested them, despite them not being a party or witness in the lawsuit and they
26 were not required by law to surrender those not evidentiary tests. Remington has written more than
27 50 sworn pages on this issue, including several dozen important interpretive cases which indicate
28 that Gans was out of line and acted improperly, but since he is a licensed attorney still all courts
that read his documents made the default assumption that he was correct and that Remington was
687
wrong, when the actual cases cited by both parties proved that Gans had no right to obtain
1
potentially prejudicial mis-information which Remington did not intend to use at trial, because it
2
was useless and unreliable on many grounds;
3
7. As explained (again) in several hundred pages of Remingtons opposition to defendants
4
collateral estoppel summary judgment motions, MIL #20 and more than 2000 pages of related
5 motion documents, Gans blatantly and fraudulently plagiarized the orders of a federal judge in
6 an effort to deceive Judge Reinholtsen and Judge Miles at the 2014-15 Summary Judgment.
7 Ultimately it worked, because Judge Reinholtsen finally ruled in their favor, Remington believes
8 erroneously. The error issue, or not, will need to be determined by a state appellate court or
9 preferably much sooner by this court; however, the fundamental plagiarization of Federal
10 Magistrate Vadas clear orders, by deleting about 10 of said federal judges words at the end of a
critical sentence which defined a case ending ORDER, and then Gans rewriting them in his own
11
words, with a totally different meaning was clearly an obstruction of justice, and because it
12
occurred regarding a federal case issue, it was therefore instantly a RICO federal predicate act.
13
Again, many hundreds of sworn pages have already been written on this issue in the state
14
cases to date, and therefore Gan enterprise is just as familiar with this issue as Remington is. As
15 Gans legal leadership fully understands, Gans selectively and very carefully made a gravely
16 self-serving fraudulent deletion of about 15 of the federal judges words and then he did a total
17 entirely false rewriting in his own words of the most important and material statements in the
18 federal judges summary judgment order, and then put his own words in quotation marks along
19 with the judges, producing the intended effect that Gans self-serving remarks were actually
20 written by the federal judge as part of his order, rather than as part of Gans very serious
fraud. Had what Gans wrote actually been what the federal judge wrote, collateral estoppel might
21
have been guaranteed immediately, but as explained above it was eventually received about a year
22
later, largely based upon that plagiarism.
23
That intentional fraudulent plagiarism by Gans had the intent and quickly also the actual
24
unfortunate effect of fraudulently obtaining a favorable collateral estoppel effect in the state case,
25 where GANS entire motion was both frivolous and fraudulent from its inception, however it
26 prevailed anyway based on that fraud plus other gross misrepresentations and falsehoods
27 complained of above. No clearer example of Gans fraud against Remington and the courts could
28 be imagined than the above, and since that series of fraudulent acts by both Gans and Plotz over

688
several months occurred in December 2014-15, Remington regards them here as clear RICO
1
predicate acts even before the depositions of the guilty parties named above.
2
The above plagiarism is admittedly and obviously difficult to explain clearly and concisely
3
and always has been. It takes about five (5) sworn pages, and exact reproductions of the actual two
4
different material plagiarism which Gans and Plotz perpetrated upon the courts to illustrate and
5 reproduce exactly what Gans deceitfully did and how it deceived and influenced Judge Reinholtsen.
6 That has been done extensively before, because the actual judges words need to be first copied, and
7 then cans plagiarism thereof, and then the significance of the material differences need to be
8 explained also. Due to the length here already, Remington declines to do so at this time, but
9 certainly can produce a freestanding 20-page or so declaration, and in fact several of them which
10 were previously filed during collateral estoppel summary judgment opposition proceedings in the
state court, if this federal judge wants to see exactly what occurred there. Meanwhile both Gans and
11
Plotz are much more than well-aware of their actual provable plagiarism, and have been painfully
12
apprised for more than two years of the charges being made against them on this issue.
13
For now, Remington alleges it is a serious federal predicate act and criminal
14
obstruction of justice with the intent to deceive Judge Reinholtsen and destroy Remingtons
15 entire state case, and to date it has succeeded in that objective, because said Judge has now
16 inferentially, but not yet finally, granted the enterprise their collateral estoppel summary
17 judgment, which is bogus, and error but nevertheless stands today. When or if Gans or Plotz
18 attempts to dispute this point and writes some sort of an oppositional rebuttal under penalty of
19 perjury, at that time Remington will provide another 20-50 SWORN pages, which has already been
20 filed under penalty of perjury on this exact topic in DR080678, which explains this entire rather
detailed issue in detail, but it is a fairly complex long topic;
21
8. Enterprise CWA frauds during 2011-2014. Gans intentionally misrepresented
22
Remingtons scientific position in the federal case with regards to the location significance and
23
dynamics of various alleged federal CWA point sources, which fraudulent misrepresentations of
24
Remingtons stated deposition and complaint positions, which occurred through 2014, and
25 substantially influenced Magistrate Vadas opinions about Remington and the validity of his case
26 In Magistrates Court, Gans default position seem to favor his arguments approximately 10 to
27 1 from 2011 on, after a variety of different frauds and mischaracterizations had percolated with the
28 magistrate causing him to decide that Remington was the bad guy and Gans Enterprises position
was just and deserve to prevail. Although Remington believes that was largely error by Judge
689
Vadas, which was perfunctorily ratified by the Ninth Circuit on strictly technical Rule 26 and 37
1
disclosure issues, which never reached any of the merits, nevertheless Remington has long since
2
accepted that strange combination and comedy of errors, precipitated by himself, but aggravated
3
by Gans unethical and corrupt behavior even back somewhat prior to the RICO enterprise.
4
Because Remington had no experts properly disclosed under Rule 2653, for reasons which
5 are beyond the scope here, and although Remington was an expert himself regarding the point
6 sources, Gans frauds caused the magistrate to discount everything Remington did or said. In the
7 federal case, Remington was not granted the courtesy of an expert qualification hearing, which he
8 can and will pass here and also in state case DR 080678, and therefore qualify as an expert in
9 several important disciplinary areas, easily. Remington is an important expert in several areas of
10 these cases and is an experienced Sloan scholar, Cornell engineer with an extremely strong and
relevant general scientific and mathematical background in useful and applicable higher
11
mathematics (more than 20 credit hours of advanced Calculus, differential equations, statistics, etc),
12
physical, organic and general chemistry, MANY physics courses, fluid and mechanical dynamics,
13
irrigation and gardening under native redwoods and hydrocarbon sampling, among other relevant
14
areas of expertise in these cases. Remington is also an experienced trucker, logger, excavator and
15 owner- operator of semi- end dump trailers and all of the equipment which was used by RAO on
16 Mathsons land in 1998 and thereafter;
17 9. Gans very significantly fraudulently deceived Remington for at least three years with
18 the false promise that he and his Blue Rock experts would be testing for hydrocarbons and
19 especially this on Remingtons land, so essentially he did not have to do it himself. When
20 Remington therefore did not do exhaustive tests in 2008-2012, because he was expecting
defendants to do them, Gans tricked Remington by not doing any himself, which left Remington
21
without sufficient information to adequately prove his case, until the last half of 201054. Finally, a
22
few weeks late, Remington eventually got the ultra-busy SHN to do some testing, and also the
23
53
Remington had plenty of experts properly designated and deposed in the state cases and had the extremely
24 mistaken understanding that all state discovery would be interchangeable with the federal case. The
25 magistrate had written that was the goal, for efficiency to collaborate with the state judge and combine all
discovery, and Remington thought that was automatic and a done deal, however never was Remington more
26 wrong in these cases. Neither state or federal judge cared about deficiency or sharing discovery and neither
did anything about it, and to this day Remington does not know who should have coordinated the sharing of
27 discovery if anyone, because obviously the judges themselves to zero initiative. Gans was not prejudiced
one bit over the lack of proper disclosure in federal court, and lied there that he had been. The truth was that
28 Gans, and his investigators knew a lot more about Remingtons experts and their opinions than Remington
knew himself, or had been able to afford to find-out in summer 2011, but the Magistrate literally scoffed at
that, and said in effect that Remingtons excuse was essentially too ridiculous to consider.
690
Humboldt County Hazmat division finally showed-up about a year late due to Brissos improper
1
influence. As discussed extensively below, Brisso exerted improper influence on Martel to
2
indefinitely delay any testing on Remingtons property until they both believe that all trials would
3
be over and Remingtons case would have been defeated. Therefore, very belatedly Ms. Hoyos was
4
finally allowed to test in late 2011, which crucial testing was denied admittance into DR080678 by
5 Judge Reinholtsen, but will be materially significant in all other cases, including this one.
6 10. Gans filed the frivolous retaliatory case DR080669 alleging visual nuisance, a minuscule
7 Remingtons mitigation pipe intended to reduce the $20,000 or more of slide damages caused
8 directly below said above Mathsons twin 6-inch drainpipes, and other purely distracting and
9 generally frivolous complaints about an ugly fence, which issue was fully resolved at least 5-6 years
10 ago. His corrupt, unethical and improper pre-RICO purpose was to attempt to offset Remingtons
valid contamination case DR080678, and make it easier for Remington to end or not even file such
11
a contamination case, than to prosecute it and in essence THAT was his earliest extortion attempt,
12
to instill fear in Remington and try to make him take his just contamination claim and go away and
13
just leave Mathsons contamination in place on his property. Nine years later, we can easily
14
understand that Gans DR080669 was merely a fraudulent attempt to link his frivolous claims to
15 Remingtons valid ones as some sort of an offset, to eliminate both cases, and two extortionately
16 prevent Remington or discourage him from filing his 2008 case at all.
17 Gans substantially failed attempt to extort Remington to offset the said two above 2008
18 cases, is also NOW an actionable obstruction of justice as Gans said above totally frivolous
19 lawsuit was seriously pursued and litigated BY defendants Gans and Plotz for many years, through
20 countless motions which ended with their fraudulent 2016 severance motion oppositions, which
were litigated in part for many years, but finally resolved in climactic February-April, 2016
21
motions, hearings and verbal arguments. As thoroughly explained above, the demise of frivolous
22
case number DR080669, escaped a horrible and certain death when Gans cleverly extorted
23
Remingtons insurer Farmers to settle his only attorney Harvey Roberts out of the case in exchange
24
for the $20,000 alleged bribe which they happily paid John Mathson in order to avoid several
25
54
In case this allegation by a pro per appears wild,unsubstantiated or unprovable, it IS a
26 verifiable fact, and the inferentially less than neutral Judge Reinholtsen in these case, DID rule
27 in Remingtons favor on this issue and kindly EXTENDED DISCOVERY BY ABOUT A
MONTH IN JANUARY 2011 to enable Remington to overcome that obvious FRAUD on
28 Remington which duped and prejudiced him to a level that even Judge Reinholtsen noticed it and
ruled against Gans furious objections on this issue, around late December 2010, as could be
provided by the supporting court motion record, not reviewed today.
691
hundred thousand dollars or more of potential Harvey Roberts expenses, which would have been
1
incurred if Roberts had sat next to Remington through 120 or more days of pretrial hearings and
2
beyond.
3
Remington has complained elsewhere of the mail fraud component of defendants
4
severance motion oppositions, but the entire DR080669 case itself was always a sham, frivolous
5 and fraudulent attempt to gain punitive damages against Remington for building an ugly fence,
6 which was based on the additional serious defendants fraudulent accusations that Remington
7 contaminated both properties by himself. Scientifically, that accusation is ridiculous, however with
8 Remingtons brilliant and preeminent expert John Aveggio now DEAD, disproving such an obvious
9 sham and scientific impossibility to a substantially ignorant and nonscientific small-town jury pool,
10 over the deceitful, dishonest and prejudice-arousing Gans RICO advocacy defense, has become
increasingly difficult, but as it has not yet occurred, we will eventually justly prevail.
11
Although Remington can doMuch of the scientific expert contamination testimony himself,
12
he often has too much passion to objectively impress and influence the jury with the truth, without
13
appearing to over-sell it. He now has an excellent, well-trained contamination expert named Dr.
14
McEdwards, who will be his primary trial expert at the next trial.
15 On the other hand, Gans specializes in perpetuating lies with a straight and sincere
16 expression backed-up by perjuring witnesses, which can become a formidable force unless
17 Remington hires numerous experts to refute that deceit, which he has done, however it is expensive
18 and frustrating to have to use them all to refute such basic impossibilities. This is another example
19 of where defendants overwhelming and unlimited financial power puts Remington at a
20 disadvantage to have to employ many witnesses to refute fictitious impossibilities which a smart
and scientific court would declare as a matter of law, based upon high school physics. For example,
21
Gans would have Remington prove that water cannot flow down the mountain, under a Creek and
22
then back up the hill 50 vertical feet, nor can two million pounds of hazardous debris just levitate
23
across a ravine by itself without some sort of alien influence. However, under Gans believable (to a
24
jury and naive court) nonscientific argument, all scientific and physics principles pretty much
25 disappear and have to be taught like in the sixth grade science class.
26 11. Gans intentionally and fraudulently confused a 2003 discussion between Remington and
27 Mathson about a fence with a specific oral settlement agreement to resolve all issues in 2007, which
28 did resolve all issues until Gans intentionally sabotaged the settlement. Gans deceived and tricked
Judge Reinholtsen into not analyzing the two entirely separate and different agreements four years
692
apart and represented them as one litigation privileged settlement agreement not subject to an
1
independent cause of action in 2008. Simply put, Gans is well-familiar with the details of that
2
successful deception and the damaging result to Remington was a $2000 special motion attorney
3
fee assessment against him by Judge Reinholtsen, which is expected to be overturned at the first
4
state appeal. This issue has been repeatedly mentioned in Remingtons 2016 motion documents but
5 Judge Reinholtsen never shows the slightest bit of interest in any sort of injustice of that type.
6 12. As discussed above and elsewhere Gans encouraged his experts to fraudulently understate
7 the amount of contamination on Mathsons property because he intended to equate that pollutions
8 magnitude with that on Remingtons adjacent property, where this lawsuit originates. Hence, the
9 lower Gans could artificially, fraudulently, and frivolously make the hydrocarbon, asbestos and
10 poisonous metal contamination values on Mathsons land APPEAR, then the lower they would be
inferentially have to be on Remingtons land, and at some point Gans could then orally reduce
11
Remingtons contamination to absurdity, which is his basic intention.
12
The basic logical fallacy in that fraudulent Gans plan was that defendants admittedly sorted
13
all of the worst contaminants onto the Remingtons property, which in itself caused a major
14
dichotomy between the two properties. Therefore any toxicity values on Mathsons property were
15 entirely irrelevant and unrelated to the tests we did on Remingtons land as explained further below.
16 For example, excavation evidence clearly shows today that Skillings carefully sorted at least
17 15,000 pounds of hazardous to ultra-hazardous asbestos pipes onto Remingtons land and then
18 concealed them with a small amount of dirt and organic debris. No significant sample of asbestos
19 pipe has yet been found on Mathsons land, which proves it was all sorted onto Remingtons portion
20 of the dump where it is rampant, seriously hazardous and causes uncontrollable coughing when
approached within 100 feet.
21
The additional scientific truth, other than the meticulous sorting of hazardous materials by
22
Skillings with his loader, as expressed by John Aveggio in more than 200 sworn pages of testimony
23
in DR 080678, is that the hydrocarbon contamination on BOTH properties is extreme, such that
24
when Blue Rock Environmental realized that during their testing, they sent their soil and water
25 samples to two different laboratories far down-south, which sent them back-and-forth between each
26 other, and then held them for 4-6 weeks in between; and, as a result 90% of the hydrocarbons
27 volatilized and disappeared on the shelf in the Southern California heat, rendering their test results
28 entirely meaningless. Scientifically, that is called sampling out-of-holding time, which for each
chemical is different but in this case for hydrocarbons, is NO LONGER THAN 14 days. By
693
deliberately violating the holding time laws, Gans and the RICO enterprise deliberately and
1
fraudulently understated the contamination results on their land.
2
Here defendants were out-of-time by approximately six weeks rendering their results
3
meaningless and incompetent. Defendants have an expert from the County Health Department
4
named Esko who argues that said Blue Rock Environmental results were and ARE not a substantial
5 health risk as to Mathsons land, and thereafter with Gans enormous lying, mischaracterization and
6 deception skills, those benign results would then also supposedly, employing false logic, apply
7 directly to Remingtons land, despite our numerous independent proper scientific testing done over
8 several years, which proved that we have a serious toxicity problem. That significant fraudulent
9 deception by Gans, Esko, Ferriman, et al, is a major part of the RICO enterprises overall action
10 plan, which now that it is understood by Remington and this court will never work, except perhaps
to subject related conspirators who are all colluding in this plan, to possible imprisonment.
11
Finally, defendants never tested or sampled at all for asbestos, chrysotile, E. coli and coliform
12
and many of the other significant hazardous materials discovered and complained of on
13
Remingtons land. Therefore, not surprisingly, all of the above named substances especially the
14
asbestos, chrysotile, E. coli and coliform and LEAD are at epidemic levels below the dump on
15 Remingtons land. The E. coli and coliform are especially dangerous to the health of
16 Remington and infects all of his water just below the dump as do the other above substances plus
17 many others named above in this complaint and in the many thousands of pages of state and federal
18 motion documents.
19 13. Gans environmental experts Ferriman and Schwartz specifically, as to this allegation,
20 made numerous false sworn statements which grossly minimized the large amount of hazardous
asbestos deposited on Remingtons property in an after 1998, which Remington knows personally
21
are blatantly false and written by Gans because Remington stood right by Ferriman for more than
22
an hour as a took repeated photographs of at least 23 different largest asbestos pipes, one Ferriman
23
signed the report that Gans wrote form lo and behold there was only maybe one asbestos pipe on
24
the sites not the 23 which photographs by Ferriman are even in the file and in Remingtons
25 possession. That type of flagrant lie and falsification is very exasperating to Remington, who hates
26 this deception and continuous criminal behavior regarding all issues, but at a trial obviously the
27 photos dont lie. In any event, aggravating as it is to have to do so, Remington can rather easily
28 prove that Gans and then his puppet Ferriman intentionally and fraudulently minimized the amount
of asbestos discovered here, and therefore its dire risks to plaintiff and public health.
694
Gans clearly wrote the declarations for all of his environmental experts, nearly word for word
1
and such gross understatements are easily attributable to him, because they are so consistent with
2
his other prior and subsequent false motion documents. Remington knows and understands all of
3
this and would therefore swear to it, mostly because Remington physically walked with Ferriman
4
on July 6, 2011 for about an hour, wherein we both saw at least 15-20 of the 23 or more known
5 substantial asbestos pipe samples which were visible on that day, about half of which were still
6 partially submerged where they had been buried around 1998. There was no doubt that defendants
7 deposited said asbestos pipes in 1998, despite fraudulent aspersions and accusations that possibly
8 Remington put some of the asbestos there on the site himself. That accusation was impossible with
9 respect to the 4-10 foot long, by 500+ pound pipes largely submerged still with just there ends
10 sticking out of the ground. Among other idiotic and impossible assumptions and accusations by
Gans concerning this issue, it would have been impossible for Remington to transport 500 pound
11
pipes across the ravine and down the mountain without any cranes or other heavy equipment and
12
then bury them up to 8 feet deep in a mound of gravel and concrete debris which even a backhoe
13
could not fully penetrate.
14
In summary, Remington knows that he showed Ferriman most if not all of the major 23
15 asbestos pipes that were exposed on that day, which is proven by the fact that Ferriman took
16 numerous photographs of some of those pipes which he saw.
17 However, the declaration which Ferriman purportedly wrote a couple of months later swore
18 that he only saw possibly one asbestos pipe fragment, which might not even be asbestos. Had he
19 been in doubt that day he could have taken a sample and had it tested at any lab of his choice, or he
20 could have taken a sample of the 60% chrysotile asbestos, which was also prevalent on the site.
However, he had no doubt and it was only Gans several months later that wrote declarations
21
introducing unreasonable doubts.
22
As above, Remington was right beside Ferriman on July 6, 2011 for most of an hour looking
23
at asbestos pipes, and related objects in the area, and Ferriman studied the asbestos pipes especially,
24
with great interest, photographed them all, but had no questions and no doubts about what he was
25 seeing, other than that he was clearly troubled, which we will pursue in his trial cross-
26 examination.
27 Without writing five more pages on this topic here, simply put those false declarations with
28 respect to the amount of asbestos present, its toxicity or whether it was even asbestos at all was

695
simply an example of another material, and Gans RICO collusive fraud, which as soon as it is
1
repeated in federal discovery will become a federal predicate act instantly.
2
14. Similarly to the above asbestos allegations, Gans has made at least another 75 material
3
false statements on the stenographic record just in the 2016 pretrial hearings alone, with respect to
4
virtually every evidentiary area issue anticipated in the cases over more than 100 consecutive days,
5 as related to every evidentiary area and legal issue that arose prior to the SOL trial. More
6 specifically but without re-creating the hundreds of relevant pages issue by issue: defendants
7 submitted at least 25 bogus MILs with serious multiple mischaracterizations of fact and law in each
8 one of them, and Remington submitted approximately 180 MILs which were all fraudulently
9 attacked based on false facts, mischaracterizations and perjury, which when repeated pain this
10 federal case will cumulatively rapidly become imprisonment offenses.
During Gans, Brissos, McBrides and Plotzs comprehensive depositions, Remington will go
11
down each and every one of those deliberate fraudulent mischaracterizations in the above
12
paragraph, plus question them on several hundred other false statements that they or the enterprise
13
have made in these cases to put them under penalty of perjury in the federal case.
14
A lawyer communicating on behalf of a client with a non-client may not knowingly make a
15 false statement of material fact to the non-client.... Vega v. Jones, Day, Reavis, et al 04) 121 Cal.
16
App.4th 282, 291. Even when no duty of disclosure would otherwise exist, Where one does speak
17 he must speak the whole truth to the end that he does not conceal any facts which materially
18 qualify those stated. One who is asked for or volunteers information must be truthful, and the
19 telling of a half-truth calculated to deceive is fraud. Cicone v. URS Corp., supra, 183 Cal.
20 App.3d 194, and CITES. As described above, Gans, and his enterprises mostly attorney leadership
21 violated this principle hundreds of times in the state litigations, dozens of additional times in the
22 federal litigations and although we already have ample evidence of federal predicate acts with
respect to Gans, after the first preliminary rounds of successful federal discovery from Gans
23
directly in this case, after all of his privileges and objections have been stripped bare, we will
24
almost instantly have about 100 federal predicate acts here for Gans to defend, UNDER OATH.
25
Since Gans cannot defend any of them WHILE UNDER OATH, and therefore wisely never
26
attempts to do so, if this court takes any of Remingtons RICO allegations seriously, then when
27 Gans refuses to defend himself under oath on any of these nearly 1000 allegations, this case will be
28 over and possibly or at least attempted to be settled before it even starts. However, at this point a
mere monetary settlement for Remingtons 10 years of major emotional, LEL, entirely lost golden
696
years and related damages, which can never be remedied by minor or any amounts of money,
1
probably will not get the job done, as it might have a few years ago.
2
Therefore, Remington urges this court to do exactly what is suggested above and for scans to
3
respond to all of Remingtons hundreds of allegations herein, either in federal court hearings or
4
preferably compel him to testify fully completely and honestly in his depositions in Eureka.
5
15. Gans personal management of Mathsons spoliation crimes was captured on
6
surveillance video. On March 18, 2016 at 8:12 and 8:32 AM on several different cameras, Gans
7 was seen trespassing on the contaminated sites and studying John Mathsons evidence spoliation
8 of said sites with great satisfaction on his face. Good job, John, you followed my orders
9 perfectly. But a month later, on the pretrial record Gans proceeded to lie about that to the court, as
10 to all relevant recorded facts and his, or his two companions, large strange footprints found where
11 defendants encroached and violated no trespassing, violators will be prosecuted signs.
16. Additional criminal trespassing by the RICO defendants. Misha Schwartz, Gans
12
asbestos expert from Winzler and Kelly also is known to have trespassed inside Remingtons fence
13
on Remington property after accessing it through one of Mathsons two major secret doors.
14
Although he was named as an expert during the last official authorized investigation of
15
Remingtons property on July 6, 2011, Schwartz did not show up on that day but made one or more
16
unauthorized, unlawful and improper trespassing entrances prior to his federal summary judgment
17 declaration, several months later, sometime prior to September 2011.
18 Naturally, Gans has lied about that improper expert work which was completed several
19 months too late to be admissible into any case, and did so LIE in the federal case from 2011-2014
20 and repeatedly again in the state case, most recently in March-May 2016, where the issue was
21 briefed quite extensively. Remington repeatedly complained about that issue to judge Reinholtsen
22 in pretrial hearings and when said Judge asked Gans about it on one occasion Gans did not answer
and change the subject such as to prove that Remingtons accusation was correct. Nevertheless,
23
obviously not wishing to anger or embarrasses former law partners, once again Judge Reinholtsen
24
went on to entirely ignore the issue several different times, strangely never ruled on it in writing
25
although it was obvious what the truth was, but overall he appeared to acquiesce to and agree with
26
proximately 99% of any positions which Gans took during those pretrial hearings.
27 17. Gans Court room spy brazenly and clandestinely canceled an approximately
28 March 1, 2016 severance hearing while Remingtons attorney was holding on the telephone

697
waiting for to start! What level of power does it take for a cord executive to brazenly cancel a
1
hearing where Remington was expected to prevail?
2
Gans saboteur in the Humboldt County Superior Court canceled the Severance Hearing
3
which was intended to decouple and un-consolidate DR080678 from DR080669, in March 2016,
4
while Remingtons Attorney Harvey Roberts was patiently holding on the phone for 30 minutes,
5 and while the parties were sitting there in the court room waiting for said canceled hearing,
6 unbeknownst to the court. The parties and attorneys had all filed appropriate timely motions,
7 objections and reply memorandum, yet someone from Gans RICO organization had the power to
8 prevent all those documents from getting to Judge Reinholtsen, and even kept him from knowing
9 that 5-6 participants were all in the court room waiting for that hearing, or holding on the phone.
10 Inexplicably, the hearing was taken off calendar by someone and Gans and Brisso already
knew they were going to settle- away their frivolous case DR 080669, and defendants clearly did
11
not want that hearing to take place in any event. Gans did not want a severance hearing or ruling on
12
the topic which might obstruct his extortive settlement complained of elsewhere herein, so he
13
arranged to have it canceled apparently without the judges knowledge and certainly without
14
anyone on Remington side aware of that illegal and felony obstruction of justice, arranged by Gans.
15 When Remington and the parties eventually told Judge Reinholtsen why they were sitting
16 there in the courtroom, it was then too late for hearing, the judge did not have the time available and
17 Harvey Robert said ended his long hold after more than 30 minutes. As above, Gans enterprise was
18 happy about all that because they would have lost that motion and already were far along with their
19 eventual $20,000 bribed and extortive settlement wherein they paid John Mathson and Gans that
20 sum to get rid of Harvey Roberts as explained in detail above. All of that was good for Farmers and
Gans but extremely prejudicial and detrimental to Remington, as explained above.
21
18. Additionally, Judge Reinholtsen ruled on November 15, 2016 that the Superior Court
22
was ordered to send Remington a copy of the minutes from that hearing, because Remington was
23
not in attendance. Remington waited several weeks and then left four different phone messages with
24
Joyce, one of the head court clerks for Department eight, which phone calls were never returned
25
nor was the message or Judge Reinholtsens order ever executed by her or anyone at said Court,
26 Remington being occupied with this RICO motion decided not to waste a precious half a day
27 writing letters or making phone calls trying to determine what had happened on November 15th,
28 which although of interest still, is not that critically important at this point but will certainly be
pursued in person with the judge at the next hearings.
698
19. Mathsons unlawful and unpermitted septic system. Gans has consistently fraudulently
1
concealed John Mathsons substantial criminal act of building and then using his backyard
2
unpermitted septic system which he feloniously built anyway, after the Humboldt County Building
3
Department correctly denied his permit because his land would not percolate properly. Nothing
4
exemplifies Mathsons and Gans illegal RICO attitudes better than this incident where
5 Mathson applied for a permit, but it was rejected by the County Health and Building Departments
6 on proper scientific and health grounds, but then they went ahead and spent $6000 to build it
7 anyway, and got away with it for many years.
8 Mathson was totally protected in Eureka by Gans and most especially by Brisso, who can
9 get away with anything in this county, and their entire RICO enterprise as named herein. But,
10 hypothetically, suppose Mathson was a bearded resident of Southern Humboldt County, who was
usurping legal County Health regulations. IF SO, Mathson would have been confronted at gunpoint
11
by Sheriffs deputies and quite possibly would have been shot or killed over that incident. Instead,
12
here in suburban Cutten, California, anything that Brisso wants is fully condoned and allowed.
13
Mathson has arranged a free-pass for himself wherein he can unceremoniously and illegally
14
allow his untreated infectious bacterial-related wastes to ooze and permeate onto and into
15 Remingtons land and water supplies used to irrigate his plants, infectiously contaminating
16 Remingtons water to the south, gravely sickening Remington, which nearly resulted in his death at
17 least twice in recent years.
18 20. Gans has lied and fraudulently represented to at least three courts that Remington
19 never did any contamination testing on his land! Obviously that claim is ridiculous because
20 how can you file contamination lawsuit without doing a single test? Clearly, you cannot, and
Remington did numerous tests.
21
Gans has repetitively, offensively and falsely stated over many years that Remington
22
never did any responsive testing on his property at any time, when the plain, known true facts are
23
that Remington did substantial, sufficient, accurate and consistent testing in every year from 2008-
24
2011 and Gans incessant false and intentional generalized deceptions perpetrated on both the
25
federal and state court from 2012-2016 are a lie, fraud on the court and improper material statement
26 from a California advocate. Lying is not only tolerated but permissible in Judge Reinholtsens court,
27 at least if it comes from Gans side of the table, and Remingtons 8-10 oral and complicated and
28 long written complaints over the years about this exact issue have always been ignored. In this
federal case, Remington will restate this and the several hundred other material issues described
699
herein to Gans in Special Interrogatories, Requests for Documents, Admissions and at a lengthy
1
oral deposition, and when Gans essentially refuses to answer that will be evidence in itself,
2
especially if this court forces him to respond during the numerous anticipated motion to
3
compel hearings. Heretofore, Gans has been protected and coddled by the attorney-client and
4
litigation privileges, but not here in this RICO action, were neither apply since he is a primary
5 targeted defendant who just happens to be a corrupt lawyer also.
6 Since he could not be any more guilty here, therefore Gans must and will refuse to say
7 anything under oath until the bitter end and will probably risk minor contempt of court violations
8 before he will risk 20 years of federal imprisonment for material lies on the 100s of different
9 specific criminal allegations herein. At some point hes going to have to either swear orally in a
10 deposition or in written discovery, such as Requests for Admissions that he is being truthful on at
least the top 100 different material allegations herein, and Remington is the one that is lying.
11
Once that is on the record we will be able to make some progress here and the end of all this will
12
clearly in sight. Conclusive evidentiary proof of all Gans lies and false facts may be difficult, but
13
all we need to do is prove 4-5 out of several hundred, and where theres a will theres a way, and
14
Remington has no doubt that with his strong will, he can prove a lot more than five major
15 perjuries by Gans over a few months.
16 21. Gans environmental experts major blunder. The most significant event during
17 defendants last investigation of Remingtons property on July 6, 2011 was the so-called stick
18 test, wherein Ferriman and Gwinn stuck a stick into a stinky muck hole, smelled it and then very
19 hastily through it 20-feet off the path and into the woods, where Remington promptly retrieved
20 it and allowed himself and Gans to also sniff the apparent old degraded hydrocarbon and other
aberrant odors, unnatural in a native redwood forest. Without summarizing the 20-30 relevant pages
21
about that test, suffice it to say that it was an important test. Odor tests are valid in any scientific
22
discipline and knowing the odor thresholds of different chemicals can lead to a scientific
23
determination of approximately what concentration of what hydrocarbons were present on that day
24
in that hole, and in essence thats what was done. Today, everyone present during that stick test
25 knows that it was significant and what it meant, however Gans has always ignored it,
26 misrepresented it and has falsely portrayed said test as being unimportant, and so far has deceived
27 Judge Reinholtsen in that regard. At the next contamination trial, that will probably be about the
28 most important evidence considered by all of their experts at cross-examination.

700
Also, when all details of that test are discussed with Gans at his federal deposition and in
1
written discovery prior to that deposition, Remington has no doubt that he will be able to add
2
another fraudulent deception to the RICO enterprises objectives of concealing all truth and
3
accurate facts in these cases from the courts and juries, unless they are consistent with their overall
4
objectives of destroying Remington and his cases based on deception and false facts.
5 22. Gans March 2016 unlawful tests. As complained of elsewhere herein, Gans claimed
6 that he conducted some unethical testing on Remingtons land in March 2016, five years after
7 discovery had closed in DR080678, in order to attempt to pretend to refute Maje Hoyos December
8 2011 testing in the swamp on Remingtons lower lands near Ridgewood Drive, and also SHNs
9 similar and consistent testing in that same general area. The overall purpose of the illegal test was
10 obviously to extort Remington, try to arouse some fear that maybe SHNs and the Countys tests
had somehow been countered or refuted, however since that is not possible with any kind of tests
11
done anywhere, Gans new extortive attempt was unsuccessful. However a successful extortion is
12
not necessary to make it a federal predicate act, simply making the attempt one way or another
13
virtually every day is unlawful and intolerable.
14
Gans claimed that some impressionable, malleable young inexperienced Oregon expert,
15 named Matthew Hillyard, came all the way down here from Portland, Oregon to give Gans the type
16 of result that he needed; and, then Gans sent Remington an enigmatic, fact-free, somewhat
17 disturbing extortive letter claiming that he got the kind of results that he wanted, so Remington
18 better drop his case now, and not call any experts or attempt to admit any of his 2011 test results,
19 etc. Gans did not identify what tests that he did, where, when or what the weather was etc., because
20 his intent was clearly only to scare Remington and to infer that he had a new corrupted expert who
would refute all of Remingtons bona fide scientific testing done in 2011. Gans previous three or
21
more environmental experts refused to do that and had also been fully discredited on the other
22
grounds described thoroughly herein, hence Gans had to scour the country for 1000 miles in every
23
direction and apparently couldnt even find a California expert anywhere willing to testify against
24
our eminent experts and willing to perjure themselves for money, about the supposed significance
25 of testing done by others, and about these improper, inadmissible and five-year late test results,
26 which Gans desperately needed, and Gans had likely already written-up the results before Hillyards
27 tests were even back from the lab.
28 Like the other hundreds of similar misrepresented and lied-about material case issues
referenced in these documents, Remington will aggressively pursue these tests with Gans where
701
his answers must be sworn, either in writing or orally; and, as explained above and elsewhere, if
1
this court cooperates with Remington and allows him to put Gans under oath on these issues in this
2
federal case, then the case will instantly have to settle, because Gans cannot swear to the several
3
hundred lies and deceitful acts which he has done over the years, at least a few of which Remington
4
can absolutely and definitively proved to a trier of fact. In fact, Gans deceptions, frauds and
5 mischaracterizations are so egregious, pervasive and deep-seated that Remington really assumes
6 that the RICO defendants will force some sort of a settlement here before Gans gets near to
7 answering anything under penalty of perjury.
8 The reason for that is that Gans absolutely knows all too well, that Remington can now
9 absolutely conclusively prove some of these allegations to a criminal standard and hundreds of
10 them by a preponderance of the evidence. Also, when Remington has the large amount of time
required to go through all of his encyclopedic records from September 1998, day by day and file by
11
file it is also likely that the basic 2016 SOL trial perjury centered on John Mathson about the
12
purported twin visits by Remington to his property, which absolutely never happened, will be
13
further and more positively refuted.
14
Since Gans is VERY slippery, slick, psychopathic, clever and has an excellent and above-
15 average white-collar criminal mind, he will absolutely not allow this to go very far forward if he
16 thinks that there is a federal court that is going to actually listen briefly to Remington let alone
17 cooperate with him to compel sworn testimony from Gans primarily. Gans has become spoiled and
18 used to the several judges that pretend to listen attentively and to consider Remingtons legal
19 arguments and case authorities, while they really see him as a hated Pro Per pest that is mostly
20 just clogging-up their already totally congested and inefficient legal system. Therefore, state judges
especially, mostly just obstruct, placate and pretend to humor him while plotting the best and
21
quickness way to get rid of another obnoxious and arrogant Pro Per, that audaciously thinks he has
22
the evidence to bring down a mighty California attorney.
23
23. Gans accuses Remington of falsifying the testing on his own property, however
24
Remington did not even conduct 95% of those tests, nor was he even there while 90% of the
25
totally independent testing was conducted. Gans has illicitly, unethically, slanderously and
26 corruptly on behalf of the RICO enterprise, accused Remington of extensive and serial tampering
27 with, in some unknown, unspecified and essentially impossible manner, all of his contamination
28 and pollution evidence on both properties, in both federal and state court continuously since 2011.

702
Then Gans, in the furtherance of those multiple false, unfounded and slanderous written and
1
oral attacks, has specifically launched into that identical improper and unsubstantiated attack in
2
front of all Remingtons experts at every deposition that Gans has conducted. Gans knows what he
3
did and every deposition transcript reflects the above statements, so Remington will not belabor this
4
subject here but will push it hard during federal discovery in order to generate more absolutely
5 irrefutable federal predicate facts and acts.
6 24. The RICO enterprises fraudulent and materially understated volume estimates. Gans
7 has further committed serious scientific fraud in these cases by concealing his knowledge of,
8 collusion with and authorship of Gwinns blatantly false calculations of the volume of the
9 encroaching fill which defendants pushed onto Remingtons land. Remington has argued and fully
10 explained for probably 100 Declaration pages under oath, exactly what multiple specific errors that
Gwinn made in his simplistic solid geometrical volume calculation, which reached a frivolous and
11
nonsensical result, because he understated all three dimensions by factors of 2-5. Each error factor
12
is multiplicative and hence when Gwinn understated the average lateral dimensions (length times
13
width) by 100% each, that alone introduces a multiplicative error of four! However, Gwinns most
14
egregious error, which could not have been accidental after Remington and his experts fully
15 explained their estimates of the depth of the fill, involved purportedly using our boring depth
16 numbers to calculate the depth of the fill encroaching on Remingtons land. Again, simply put, we
17 explained very clearly all along that none of SHNs borings were actual depth of the fill numbers
18 because all were obstructed by huge concrete and other hard objects stopped all holes between 6-20
19 inches deep, where the fill in those areas was known to be 4-20 feet deep using other reliable depth
20 measurements and/or estimates.
When Gwinn calculated a volume using a depth (the THIRD volume parameter) of 12-18
21
inches when the actual depth was 4-10 times that, a further error of 4-10 times was introduced on
22
top of the already multiplicative error of four above. In other words, Gwinns volume estimate has
23
been known to be a sham and a fraud intended to deceive all courts and triers of fact the get
24
involved in these cases. It is mathematically understated by at least eight times and arguably by
25 twice that!! Luckily, Remington happens to be a mathematical expert and caught those simple
26 multiplicative solid geometrical errors in the first two minutes.
27 Misstating scientific numbers and facts, and claiming that the raw data they used came from
28 Remington and his experts, when the record plainly shows that is false and after we have explained
what the correct numbers are since June 2011, is simply-put a fraudulent deception, conspiracy and
703
a criminal act intended to defraud Remington out of money justly due him, all of which we can
1
easily prove at the trial in any court. For today, just as with the other Gans fraudulent deceptions,
2
we will formulate all of these frauds, inaccuracies and lies into written federal discovery directed
3
mostly to Gans, but also to the specific culprits involved, such as Ferriman and Gwinn, to see who
4
was willing to commit federal perjury. Gans specific frauds and all scientific areas will also be
5 directed to all of the dozen or so other presently unnamed likely future RICO defendants, as well
6 as to all of the named defendants obviously. In each case, there are at least 5-10 defendants and
7 their witnesses who knew or should have known of each of these scores of fraudulent deceptions,
8 which have been extensively written and complained about for years, and are now being reasserted
9 by the RICO defendants as fresh, viable, timely and recent federal predicate acts, and also as false
10 evidence in the upcoming contamination trials in state and/or federal court.
25. The RICO enterprises 2 million pound contaminating encroachment is merely a
11
little pile of dirt in Gans corrupt world.
12
Another favored and especially exasperating Gans fraudulent deception, which he has
13
promulgated for years and including in 2016, is to characterize Mathsons and RAOs admitted
14
major, continuing encroachment onto Remingtons land as just a little pile of dirt. That apparently
15 innocent and innocuous statement if allowed to stand in front of a court or jury would justifiably
16 lead to an immediate dismissal of Remingtons case. Gans lies and misrepresents the amount of
17 defendants enormous trespassing encroachment as though it were merely two wheelbarrow loads
18 of good topsoil, which topsoil Remington would have welcomed in his gardens.
19 Defendants encroachment was in reality nearly 2 million pounds and more than 60
20 enormous 10-yard dump loads which was equal in weight and toxicity to some of the worst,
heaviest and most poisonous hazardous wastes, ever produced in this county. They have been
21
named and fully listed elsewhere, but consisted of a large amount of gigantic, onerous 10-20 ton
22
reinforced concrete blocks, which now require a crane or large excavator to remove, large amounts
23
of septic wastes, lead, asbestos, organic chemicals, carcinogenic dusts, heavily saturated and toxic
24
hydrocarbon wastes from gas station remediation projects and similar highly infectious toxins,
25
many of which are essentially invisible, airborne or poisons dissolved in above and below ground
26 waters emanating from the dump area.
27 As far as this point goes, it is the volume, enormous weight, size of the huge chunks and
28 overall the amount of the encroachment that is being understated in Gans sentence; as he
minimizes the toxicity in other statements, and characterizes it elsewhere as essentially benign,
704
clean, unpolluted soils and just plain good dirt right out of a redwood forest, as opposed to the
1
truth which is listed in the paragraph above.
2
The true facts regarding the volume and toxicity of the encroachment have been sworn to
3
over many years by our environmental experts, however as Remingtons present expert Dr.
4
McEdwards characterizes it: We wont really know for sure exactly how much is there and what it
5 is until it is removed and looked at and bagged item by item, so therefore since defendants have
6 admittedly dumped the debris and are obviously responsible for removing what they dumped, it is
7 logical then to request that they just pay for the removal themselves and if it turns out to be just a
8 small pile of dirt such as a few wheelbarrow loads, than whats the problem? Why not just do it
9 and end these cases? If they thought it was just a few dump truck loads requiring $5000-
10 $10,000 to remove, do you think that they would spend $400,000 or more battling Remington
over it? The facts and ramifications thereof, in these paragraphs here, really prove Remingtons
11
entire RICO case and that the enterprise is deliberately and massively understating the problem
12
which they caused, otherwise they would just resolve it in a few days. The RICO defendants, if
13
anything are NOT STUPID. By definition, it would be stupid to spend $400,000 to attempt to
14
make a $10,000 problem go away, especially when its not going away. Therefore, it can be
15 logically concluded that defendants did not think they can solve the problem with $10,000 and
16 perhaps not for even $400,000.
17 Reiterating, since they refused to do it and have spent at least $300-400,000 so far battling
18 Remington on this, it may be inferred that they fear and actually believe that cleanup of their
19 mess is really going to be very expensive, and therefore they are fighting Remington to the death
20 on this volume and amount of truckloads issue, to avoid doing it. In other words, it should be clear
logically that Gans is being totally disingenuous in his understatements of the volume and toxicity
21
of the encroaching materials, because if not, they would just remove it all without complaint, and
22
we could all just go home.
23
26. As discussed in more detail elsewhere, in February 2016, Gans improperly ordered
24
his puppet-soldier John Mathson to frantically rake-up about 1 yd. of redwood needles and then
25
trespass onto Remingtons land, and there walk-them-around in 5-gallon buckets to distribute them
26 carefully out by hand, down onto the dump sites, to fully conceal each and every remaining
27 asbestos pipe at the ground surface, which Mathson had not yet already removed, presumably
28 because some of them were too heavy, buried much too deep to remove or too toxic. We now have
extensive surveillance video of all of these fraudulent concealment activities, including the exact
705
hours of the day, duration of the job and the day of the month, ALL coordinated to exactly
1
precede by only hours or minutes, Dr. McEdwards brief, expensive trip-up to Humboldt County
2
from Laytonville for his deposition. Gans well-knew that this would likely be Dr. McEdwards
3
only view of the contaminated dumpsites, and therefore if the enterprise could remove and conceal
4
all of the asbestos as though it had never even been there, then Dr. McEdwards would have to
5 acknowledge that he was not certain what was there then or had ever been there.
6 In any case, Remington now understands all details of the cover-up, Gans motives and his
7 completed objectives with regards to those series of incidents, which we will again probe in
8 appropriate discovery. It is very likely that here again we will gather some additional federal lies
9 from the obvious implicated RICO defendants during discovery, since we have absolute
10 photographic proofs in this area, which we will employ at trial after we have established additional
perjury.
11
27. Gans false premise logic strikes again! Gans has falsely alleged that Remingtons and
12
SHN tests are not valid because they were done on Remingtons property, and that the only valid
13
tests of these dumpsites are conducted on Mathsons property. Apparently that is based on the false
14
logic that if what is dumped on Remingtons property originally came from Mathsons, then what is
15 on Mathsons property today must be identical to what they sorted and selectively dumped onto
16 Remingtons land. That logic is flawed, leads to an inaccurate conclusion and the reasons therefore
17 are thoroughly discussed above. Irrespective of the false logic however, why would it not be still
18 important to do contamination tests on Remingtons land where the actual complaint arises from?
19 Mathson can also test on his land, but so what? What difference does it make what is on Mathsons
20 land, as Remingtons multiple complaints or about what is presently on Remingtons land NOT
what is on Mathsons, and the former is very different than what Mathson kept on his property and
21
planted luxurious gardens on top of.
22
Gans clever sophistic false logic deceived the federal magistrate in CV 094547 NJV, but is
23
spurious, inaccurate, unscientific and ignores the crucial fact that defendants sorted the debris
24
before pushing it down the mountain onto Remingtons land; therefore, Gans attempt to equate the
25
debris on both properties is actually the opposite of what is true for the most part in these cases,
26 although obviously there is some overlap including huge concentrations of gas station remediation
27 hydrocarbons on Mathsons property also.
28 However, never forget that this lawsuit is about contamination on Remingtons land and not
about conditions on another piece of property 100 feet away, especially where all testing there was
706
incompetently conducted out-of-holding time, as discussed above. Again, Gans understands that his
1
approach is illogical, deceitful and fraudulent, so if he repeats that flagrant and obvious sophistry,
2
as though it were truthful in his federal discovery, then he will again have a big problem by the
3
time of trial.
4
28. Remingtons lawfully election under Mangini II. Gans persists in disingenuously and
5 corruptly arguing against Remingtons lawful election that the encroachment is a remediable
6 nuisance and trespass and not a permanent nuisance. Gans knows better than Remington that a
7 proper election was made back in early 2011, and nothing has changed since then, except for
8 perhaps the fact that Judge Reinholtsen has become unduly and improperly influenced by and
9 accepts anything inaccurate that Gans says as an absolute fact, and to date has totally missed or not
10 understood at all the election issue and what its significance is here.
Gans repeated and persistent fraudulent written insistence that defendants encroachment is a
11
permanent nuisance/trespass because Remington declared it alternatively as possibly being such,
12
BEFORE his final Mangini II election was made is a serious intentional and Remington believes a
13
criminal deception. That is because because as Gans knows at least as well as anyone here that all
14
(100%) of the environmental experts that have visited the sites and studied these cases have all
15 unanimously agreed that the encroachment is easily removable, which means it is remediable
16 and therefore by definition it cannot be a permanent nuisance/ trespass. In other words, it
17 qualifies under the authoritative California Supreme Court contamination law, under the Mangini II
18 cases and their offspring, as a continuing nuisance/ trespass, which causes continuous and
19 continuing damages, until it is removed.
20 29. Gans perpetually lies that Remington never did any tests on his property, when the
evidence shows that many tests were done. Ever since about 2008, Gans perpetually falsely claims
21
that Remington has not obtained any competent soil or water tests prior to 2011, which he knows is
22
provably false with respect to the Stevens Ecology tests, the University of Massachusetts tests, the
23
Western Analytical Laboratory tests, the numerous SHN early anecdotal tests of the entire area
24
including Remington Creek, among others described at length in Remingtons declarations. Like
25
all of the other issues complained about herein in this section, every time Gans falsely asserts these
26 claims he is committing frauds on Remington and at least three courts in the pursuit of their RICO
27 enterprises objectives, which simply put is to win these cases unconditionally, win DIRTY, and to
28 destroy Remington during the lengthy process.
30. Gans stupid and discredited false claim that diesel and gasoline are really asphalt!
707
Gans experts claim, in a disingenuous script written for them by Gans for their signature,
1
that the only hydrocarbon on Remingtons land is asphalt and that it mimics diesel and motor oil
2
molecules in the gas chromatography tests and hydrocarbon molecular weight laboratory studies.
3
In other words, our lying tests are coming from accredited labs which are too stupid to
4
understand that what looks like diesel, gasoline, benzene, xylene, etc, under a microscope, when
5 burned as a vapor, and in an every other modern sophisticated scientific testing method proves, and
6 as based upon molecular weight is really not what it appears to be and actually IS, at all, but it
7 is all just benign asphalt because Gans thinks that fits his false play script.
8 Our experts, especially the eminent John Aveggio, have all proven that Gans stupid, self-
9 serving and blatantly false narrative, obvious misrepresentation and bogus scientific interpretation,
10 is merely a successful attempt to deceive the courts and a jury, who seem to be inclined to believe
almost anything that Gans spouts out of his mouth. We will state all that succinctly in sworn
11
discovery to see if the RICO defendants, specially their experts want to commit federal perjury,
12
conspiratorial collusion and other frauds over these obviously false and frivolous scientific claims
13
in artfully drafted by Gans many many years ago, and which are patently increasingly false on their
14
face, with every additional analysis.
15 31. During the 2016 SOL trial several RICO defendants acknowledge that they
16 contaminated Remingtons land, just not as badly as Remington has alleged, or something like
17 that, i.e less hazardous wastes and not as hazardous as alleged. That was progress, and in essence
18 defendants fully admitted liability, which makes sense, because obviously they were the only ones
19 that could possibly have dumped 2 million pounds of hazardous waste in that remote area which
20 was inaccessible to Remington. What doesnt make sense is why they are still battling Remington
over this and not already removing their debris that they acknowledge they dumped, buried and
21
then further clandestinely concealed on Remingtons land.
22
Gans, the contamination defendants and the RICO defendants have never fully acknowledged
23
in writing that they deposited on Remingtons land ALL that our lying eyes and tests have
24
proven, which is that they contaminated Remingtons land with friable asbestos, benzene,
25
underground service station fixtures, including a Lube Bay underground hydraulic cylinder
26 discovered by Gans himself, one UST rolled all the way down the mountain into Remington
27 Creek, underground rusty gas station piping, high concentrations of all types of degraded
28 hydrocarbons from about 30-80 years ago, E. coli, coliform, lead, toxic levels of several other
heavy metals, etc.
708
Ironically, they now in 2016 for the first time have admitted that they dumped a huge amount
1
of debris onto Remingtons land but now defendants are nitpicking on what that was and whether
2
Remington wheelbarrowed over across the deep impassable ravine other objects weighing many
3
thousands of pounds, which Gans presently has not admitting to dumping there! Well, where else
4
today come from then? When that issue came up at one point during 2016 pretrial hearings again
5 made the inference that maybe the stuff had been there for a couple hundred years and was left by
6 the Indians, however on many different levels none of that makes sense since defendants
7 acknowledge they imported a massive amount of truckloads of junk in 1998, and possibly they
8 didnt identify, categorize an index every single hazardous item which was dumped along with
9 70,000 pounds of other debris and just one semi-end dump load.
10 Shortly we will see if Gans will deny those facts in a sworn Request for Admission or not,
with a court that is impatient over frivolous objections, which will absolutely undoubtably result in
11
Gans not making any substantive responses to any properly worded discovery question, so then will
12
quickly schedule a deposition.
13
Even more interesting though will be all of the lesser defendants and the other as yet
14
unnamed likely defendants and experts and whether they want to start making false and deceptive
15 answers to federal discovery and depositions, with all the risks that entails.
16 32. Enormous real estate value drops. It is an absolutely proven fact since 2011, that both
17 the Mathsons and the Remington properties real estate values have been drastically reduced in
18 value and are both entirely unmarketable today as they are presently contaminated. Gans will be
19 soon asked that question and presumably he will be sanctioned, if he refuses to answer such simple
20 questions if properly worded and defined. However, Remingtons been down this road with Gans
many too many times, and knows that his specialty is quibbling over all discovery terminology and
21
making no answer to 99% of the questions. Therefore most written discovery will be aimed at other
22
witnesses who may decide to become whistleblowers in order to save themselves, and get some
23
kind of immunity as early as possible, while it is still possible to get.
24
Remington had always believed in written discovery as being a valuable and efficient
25
information gathering tool, until he encountered Mr. Gans. Since then, its become quite obvious
26 that battling Gans verbally at depositions is probably a more efficient way to invest or perhaps
27 waste his time and money, than reading a hundred pages of the same injection repeated five times
28 per page.

709
33. Gans and Blue Rocks leaching and extraction tests are fringe-science, not accepted
1
in the scientific community, were fully rejected by John Aveggio at his two depositions and in these
2
cases, they prove nothing and are merely introduced by Gans to mislead judges and distract from
3
the nearly 2 million estimated pounds of defendants encroachment NOW ON Remingtons land
4
today, alone. In fact, John Aveggio and Dr. McEdwards would probably put it much stronger than
5 that and argue that Gans emphasis on bogus leaching and extraction tests are merely a thinly
6 disguised scheme to avoid the real issues and to defraud the court. In this case, there are 2 million
7 pounds of hazardous wastes already deposited on and migrated onto Remingtons land and no
8 further migration or leaching is required to form a cause of action, despite Gans distractions and
9 frivolous arguments to the contrary. Every year however many tons of hazardous debris change
10 position, and slide lower on the Remingtons land contaminating more of it every year, mostly due
to slides and a huge amount of water and wind erosion.
11
We will put those facts logically in a request for admission which simply put would be: Why
12
is any additional leaching and extraction movement of molecules necessary where there is already
13
1.4-2 million pounds of hazardous debris presently deposited on Remingtons land, on his side of
14
the Pulley boundary, such that any additional migration, leaching or movement is not necessary to
15 prove a trespass. The trespassing debris is already here, and requires removal!!!
16 34. It has been very well documented since 2009 where defendants contaminated water
17 emanates from. Gans and the RICO and contamination defendants well-know that the documented
18 contaminated hydrocarbon discharges in the water flowing off of and beneath Mathsons land onto
19 Remingtons did not come from the twin, solid non-French drain pipes, as once believed possible
20 back before any actual studies had been done, but provably and traceability came from other
polluted sources on Mathsons land on either side of and below said twin pipes.
21
35. Asbestos and hazardous material present now. As Gans knows all too well, Remington
22
and SHN have tested for and positively confirmed the presence of toxic lead, iron, other metals,
23
Asbestos, chrysotile and other deadly compounds in both soils and waters below and within
24
Mathsons dump on both properties. Gans will be asked to confirm or deny that and to provide his
25
reasons if he decides to cleverly attack the wording and risk committing perjury over our provable
26 scientific results, and testing which he knows as well as we do.
27 Additionally, since especially this in chrysotile were undiscovered and not mentioned in
28 either the 2008 or the 2009 complaints, obviously they could not properly be eliminated by
collateral estoppel originating several years later. Additionally as will be raised in the future
710
opposition to dismissal documents herein, collateral estoppel goes backward from the time of the
1
ultimate decision in 2014 in this case. Therefore it does not apply forward to DR140426 which is
2
an entirely different lawsuit, with different parties, different tests, all different facts and in any event
3
there are zero issues that are identical to anything determined in CV 094547 NJV, nor are they
4
identical to any issues from DR 080678, either.
5 36. Gans intentionally fraudulent falls 250-yard NON permit to do anything. Gans
6 has falsely represented over the years that defendants dump was legal and authorized and that there
7 purported 250-yard agreement was permission from the county to establish their toxic hazardous
8 waste dumps on both properties, and then to violate the total volume deposited there by at least 10-
9 20 times! How Gans responds to a properly worded federal discovery request which puts him
10 personally under penalty of perjury and risking imprisonment, will be essentially worth the price
of admission. BUT, since he wont respond honestly, this whole case will be about technical
11
wording and motions to compel, which Remington will indeed become expert on while drafting his
12
form motion to compel documents, and waiting for the court to become impatient with Gans
13
known tendencies and anticipated refusal to respond to any conscientious and proper discovery
14
request, ethically or honestly. Meanwhile, as discussed and thought through further above, wasting
15 time with written discovery on Gans is probably inefficient and stupid, so we will probably focus
16 on his first deposition and do a motion to compel there.
17 37. Remingtons entire 2008 complaint was not verified nor were any of this complaints
18 in any of the cases. Nevertheless, Gans persists on falsely stating that all of Remingtons complaints
19 were verified, and then proceeds to undermine them based on hyperbole and trivia, undermining
20 them and then inferring that Remington was disingenuous in verifying them! Perhaps we can put
that issue to rest for good with one simple request for admission directed at Gans personally under
21
federal penalties. Otherwise, a deposition will work even better.
22
38. John Mathson is a perjurer, and we are going to prove it here under federal
23
penalties. John Mathson committed eight (8) provable at trial deposition perjuries during 2010
24
which at the next trial will be proven and confirmed by our independent expert Mensa photography
25
witness Filiar. Mathson is also of course a confirmed known serial perjurer from the 2016 trial
26 and from numerous other earlier false sworn documents, including his significant fraud and perjury
27 about the twin backyard drainpipes. Remington looks forward to the challenge of introducing these
28 facts into the federal contamination and RICO trials, and prior to that in federal discovery.

711
39. Remingtons 2012 notice of appeal was timely filed but intentionally lied about by
1
Gans in the Ninth Circuit. Inferentially, they saw through Gans disingenuousness and
2
misrepresentations about every aspect of Remingtons case, and as a result they ruled in his favor on
3
at least a dozen pre-decision administrative skirmishes. They eventually perfunctorily accepted the
4
magistrates decision regarding Rule 37 (b) dismissal, but otherwise did not agree with anything that
5 Gans said or wrote. Many of those pre-brief frauds against Remington and the Ninth Circuit are now
6 relevant as potential federal predicate acts, obstructions of justice, and/or precursors to or near
7 federal predicate act, which show that Gans was corrupt then and still and has become exponentially
8 increasingly so, by 2017.
9 40. Additional major Gans dishonesty and false statements of many facts in the Ninth
10 Circuit. Again, not arising to the criminality of a federal predicate act, but showing background and
long-time illicit intent, and essentially proving Gans corruption and disingenuous advocacy practices
11
going back at least as early as 2012, Remingtons Rule 60 (b)(1) (3) (6) 2012 motion in CV 094547
12
NJV properly and legally qualified as a Rule 4 (a) (1) (A) motion which tolled the time Remington
13
had to file an appeal to the Ninth Circuit, however Gans disingenuously, strenuously and dishonestly
14
argued the opposite, however in that instance the District Court, Magistrate Vadas saw that
15 dishonesty and ruled against him. Remington also won at least six other important procedural
16 motions in the Ninth Circuit regarding the filing of the briefs, however eventually lost the war
17 because apparently district judges have unlimited power under Rule 37, whether factually and truth-
18 based or not.
19 41.Remington has never been solely responsible for any events in these cases. Gans
20 repeatedly falsely and disingenuously lied that Remington was solely responsible for continuously
delaying the state and federal proceedings, which Gans falsely alleged in his Ninth Circuit
21
opposition dated 10-23-12. Gans will now be asked under penalty of perjury to reassert those false
22
charges including his proofs, evidence or lack thereof. There are at least 200 instances where
23
Remington will employ that practice to prove that Gans is essentially a gigantic liar, and when hes
24
not lying he is misrepresenting, mischaracterizing or otherwise deceiving the court about much of
25 what he writes, but not all obviously. However, again the basic principle is as follows: If someone
26 talks to you for 10 minutes and tells you nine things of interest, but then smashes in the mouth
27 knocks you out at the end of it, what do you remember about that and was a crime committed?
28 42. Gans RICO enterprise and its precedents argued that Remingtons state claims
were clearly dominant for about four years in federal court and then improperly and
712
unlawfully reversed that well-estopped position hundred and 180 during state proceedings in
1
2014-16. Gans and Brisso for several years, especially in 2009 dismissal motion documents,
2
vociferously argued the truth here that Remingtons state claims are clearly dominant in most
3
respects and were also very different from the federal statutory environmental claims. But, by 2012-
4
2014, defendants attorneys had exactly reversed that position, and argued the opposite. That is
5 improper and impermissible for an attorney to take the exact opposite side of the position several
6 years apart with no intervening factual changes whatsoever. Under penalty of perjury, Remington
7 wonders about that, and will ask all said RICO attorneys during their depositions which is their true
8 position and belief? Is black white, or is white black?
9 In other words, Gans and Brisso disingenuously argued back in 2009 that the state law
10 claims predominated, but by 2014 to 16 Gans has argued that the exact reverse is true: now the
federal claims predominate sufficiently to overshadow and erase, via the frivolous application of
11
collateral estoppel, all of Remingtons hundreds of independent state common law, tort, personal
12
injury, general and compensatory damages and costs as listed.
13
43. Similarly, defendants initially argued for at least four years that Remington state
14
claims were very different from his federal claims, but then exactly diametrically reversed that
15 position beginning in 2014 and continuing through the present, where they now argue that all claims
16 and issues are and always were identical. Moreover, Gans and Brisso similarly successfully argued
17 and prevailed in 2009 on their position that Remingtons state claims are very different from the
18 federal claims and issues and therefore predominate here. However, by the time of their 2014-2016
19 collateral estoppel motions, said attorneys, and the entire RICO enterprise disingenuously,
20 opportunistically and unethically exactly reversed that position, which we will prove during
discovery and trial.
21
That is, in 2009, Mathson Gans and Brisso explained authoritatively and at length that
22
Remingtons primary state claims are totally different from and independent of the federal claims,
23
and the only new legal claim brought by Remington was under EPCRA, Gans SJ motion in
24
2014-15.
25
Today, both Gans and Plotz vehemently assert that all of the issues from the state and federal
26 cases were and always have been identical and on June 2, 2016 they apparently convinced Judge
27 Reinholtsen of that error, finally gaining an erroneous collateral estoppel from MIL # 20. The RICO
28 enterprise has no morality or conception of truthfulness, and it is second nature for Gans to argue
one day that defendants contaminated both properties, and on the next day argue that defendants
713
were innocent and Remington was the one that contaminated both properties despite the scientific
1
impossibility of that. Truth, logic and science have no real truthful meaning to Gans who persistently
2
ignores all three, and then can trick both state judges and impatient jurors easily into believing
3
almost anything he says, while using his own false and nonscientific morality and fact system.
4
44. The Federal Magistrate clearly split plaintiffs environmental causes of action into at
5 least two and arguably three parts by himself, but the RICO attorneys and Judge Reinholtsen
6 decided to ignore thatLawful splitting and ruled that everything was one. Judge Vadas claim
7 splitting set a precedent, which now must be adhered to because it is the federal district court
8 which now controls the law to be applied in state court to Gans frivolous res judicata attempt.
9 Judge Vadas clearly preserved all of Remingtons state claims for adjudication in state court
10 and it is logically obvious that he also preserved all necessary underlying evidence to prosecute
those claims in state court wherein he never admitted any of Remingtons evidence and never
11
considered any issues beyond the federal statutory claims on the merits. Even when he ruled-on and
12
dismissed Remingtons federal claims he did not look at specific evidence or merits but just
13
concluded the obvious that, without any evidence or experts Remington could not prove anything in
14
federal court. Judge Reinholtsens complicated and failed attempt to understand what the magistrate
15 did or to grasp the relationship between federal summary judgment orders and Remington state case
16 DR 080678 is probably the primary reason that Remington has brought this action.
17 Judge Reinholtsen erroneously attributed great wisdom and carefulness to the magistrates
18 lengthy but totally one-sided summary judgment order, and then Remington believes he wrongfully
19 attributed great wisdom and merit to obvious rambling federal obiter dicta, intended to sustain the
20 magistrates federal statutory decisions, based solely on Remingtons Rule 26 disclosure failures
which wound-up leaving Remington in the untenable situation of not being able to present one single
21
piece of any evidence of any kind, but nothing else.
22
Obviously such a one-sided federal decision disallowing five federal statutory claims could
23
not be fully dispositive of all of the numerous unrelated state claims and damages, which Remington
24
had more than ample evidence for, and he had also fully proven all of the state claims for about two
25
years before the magistrates independent decision in an essentially unrelated case, correctly stating
26 that with out any evidence Remington could not assert any federal claims. However, the magistrate
27 very carefully and on three different occasions ordered that Remingtons state claims would stay
28 viable for a decision in state court, but judge Reinholtsen dismissed that order as irrelevant, which
again was probably further error in Remingtons opinion.
714
47. In 2009, Gans and Brisso urged the federal court to reject all of Remingtons federal
1
claims and properly leave all state claims for adjudication in Humboldt County Superior
2
Court. That was logical then because as they acknowledged state discovery was far-advanced,
3
no discovery whatsoever occurred in federal court nor did Remington ever attempt to do anything
4
substantive there, until it was too late. Remington had all of his experts fully in place in state court
5 and erroneously assumed that that would apply in federal court, and that Gans would agree that he
6 had not been prejudiced by any Rule 26 non-disclosures, because the fact was that Gans was not
7 prejudiced in any respect. However, Gans again disingenuously argued great prejudice and the
8 Magistrate bought that false argument. Here, Gans will now have to explain and prove what great
9 prejudice Remington subjected him to that warranted the obviously unjust result full dismissal by
10 summary judgment.
48. Gans improperly deposed Remingtons environmental expert Aveggio on federal
11
issues during his last state deposition, and then corruptly use that testimony against
12
Remington at federal summary judgment despite the fact that Aveggio and all of his work was
13
kicked out of the case, had been denied use by Remington, but suddenly it was just fine for Gans
14
to use him, when he was not even a witness in the federal case.
15 One of the very major reasons for federal summary judgment in 2011-2014 was that Gans
16 improperly and deceptively deposed Aveggio on the most crucial federal issue in that lawsuit in his
17 state deposition which had been approved by the state judge, at a time long after federal discovery
18 had concluded. Gans improperly asked Aveggio about imminent threats under RCRA at the July 1,
19 2011 state deposition where that subject was initially improper and irrelevant but became more
20 important after Aveggio was fully barred from the federal case, about a month before Gans federal
Summary judgment in August- September 2011. Remington desperately needed him to oppose
21
Gans frivolous summary judgment, however the magistrate barred him based largely on Gans
22
simultaneously false statements in his protective order motion. Gans still used him in his offensive
23
summary judgment case, as explained above, and also very significantly quoted Aveggios then
24
totally honest but totally improper to use here (and fully BARRED) state deposition, and then very
25 unethically used that improper barred state deposition testimony, with seriously deleterious effect
26 against Remington, and that testimony proved to be an important factor in Gans gaining his unjust
27 federal summary judgment against Remington. Then, on top of that Gans and Plotz improperly
28 applied all of that to get collateral estoppel in the state case, which is essentially unethical behavior
on top of improper and corrupt behavior to get a truly unjust result.
715
Probably there is a RICO predicate act here or close to it when we get Gans to honestly
1
comment about his whole train of corrupt activity above, what he did, why he did it and whether it
2
was legitimately in good faith or not. Again, as above since Gans cannot answer or defend any of
3
his actions truthfully without getting himself into deeper trouble, Remington will structure questions
4
on these different issues in order to trap him into provable perjury on one or more of these hundreds
5 of major problem areas for Gans.
6 49. Gans violated Rule 26 in multiple ways himself, but fully got away with it in federal
7 court. Violating Rule 26 was what got Remingtons case thrown out by the magistrate, and Gans
8 did the same thing with the same punishment under the statutes, when he deposed Aveggio before he
9 got his report. Under Rule 26, if a deposition is taken prior to receipt of said expert report then
10 said report is thereafter waived if the deposition is scheduled first as occurred here.
Remington raised that technical issue with the magistrate, but by that time it was too late as
11
Gans had already totally biased the magistrate against Remington, such that all the former could
12
think of by August 2011 was how to get Remington out of federal court as painlessly and quickly as
13
possible. In other words, the magistrate totally stopped listening to Remington during August 2011
14
and despite three different major reconsideration motions, the magistrate never wavered from any of
15 his errors or ever acknowledged the many mistakes that he admitted that he had made in his order,
16 such as being unable to find Remingtons personal sworn evidence because he could not understand
17 a basic indexing system. The magistrate kept looking for Remingtons responses to specific Separate
18 Statement issues at section numbers, mistaking them for page numbers. Generally speaking, said
19 magistrate was not really intellectually up to the job and certainly did not relate to Remington or
20 understand his writings even as to such basic elements as determining the obvious and clearly
indexed and FULLY EXPLAINED differences between section numbers that went up to about 100
21
with the page numbers that went up to about 250.
22
Additionally, Gans heavily used and relied upon his asbestos expert Mischa Schwartz,
23
although asbestos was never even officially involved in the case through Remingtons complaints,
24
and was not even discovered or understood at all until long after both initial complaints had been
25
drafted. Further, Schwartz was never designated at all under Rule 26 nor was he even mentioned
26 before the close of discovery and never even visited the sites erode any reports until months after
27 discovery had fully closed. In Remingtons case that was a fatal error which led to automatic
28 summary judgment dismissal, but again, when Gans was involved, the magistrate didnt care and
allowed the undisclosed asbestos expert to opine for many pages about asbestos, which as above was
716
never even an issue in the case, nor was it proper for Schwartz to enter any opinions at all. Here
1
however, not only did Schwartz dominate Judge Vadas summary judgment order, for many pages
2
about an issue not even in Remingtons complaint, but said judge was strongly influenced by him,
3
however Schwartz was an undisclosed expert and did not belong there any more than Remingtons
4
expert Aveggio did at that point, because of Rule 26 disclosure failures.
5 50. Gans lied about being prejudiced by Remingtons not providing proper Rule 26
6 expert reports in 2011. In fact, Gans had not only all of the expert information that he needed with
7 respect to all of Remingtons trial experts but he had more information than Remington himself did
8 about Remingtons own experts as came out at the several July 2011 depositions. In that regard,
9 Gans stated in his federal protective order motion in August 2011 that Remingtons opposition
10 confirms he intentionally did provide expert witness reports. That was another way of saying, via
Freudian slip that Gans had all of the expert reports from Remington that he could possibly use for
11
a trial in July 2011 and he needed nothing more.
12
51. Additional Gans deceit and deception in federal court. Gans first misrepresented his
13
supposedly great prejudice to the federal court, and then on September 13, 2011 he further
14
complained that he could not read depositions and pleadings in the state action to learn what
15 Remingtons experts would say there, because obviously, there are significant distinctions
16 between plaintiffs federal claims and his state court trespass and nuisance claims.
17 As possibly the careful reader, if any, will note, that statement is totally inconsistent with all
18 of Gans other misrepresentations discussed several pages above. Gans deceitful misrepresentations
19 actually know no bounds. In fact, by 2014-15 and 16, all that was forgotten and entirely reversed.
20 Now (today) all issues in both cases have suddenly become exactly identical, so
identical that collateral estoppel was justified and granted. Federal discovery will attempt to discern
21
what exactly Gans really believes is the truth in that regard, because both contradictory statements
22
and positions cannot be true anymore than the five or six above contradictory statements can ALL be
23
true. Trying to get to the bottom of Gans deceitful criminal mind will be a difficult challenge, but
24
one Remington is ready for and motivated to conquer. Obviously Gans has no right, wrong, actual
25
facts even permanent false or fake facts which he can consistently use for years. He therefore
26 jumps back and forth and all around on most of the case issues and how he swears to all of that
27 and tries to make it consistent or truthful in a federal sworn deposition will be truly remarkable to
28 witness! However, tricky and slippery as he is, we will catch-up with him eventually with enough
preparation.
717
52. The magistrate made numerous egregious errors, some of which were admitted but
1
none of which were reconsidered over a six-month reconsideration effort.
2
Another huge reason for the federal summary judgment were the numerous errors and
3
mistakes which were admitted to in writing by the magistrate, wherein he literally, strange and
4
improbable as that sounds, could not find most of Remingtons evidence in his to lengthy Separate
5 Statement Opposition Declarations, which were Remingtons responses to Gans Separate Statement
6 remarks and outline which the magistrate erroneously concluded Remington had ignored, because he
7 had no answer to anything Gans stated as facts.
8 Nothing could be further from the truth, as Remington had every Gans supposedly
9 undisputed fact fully refuted many times over, however the magistrate just could not find
10 Remingtons answers. Said answers were right there in plain sight and it was absolutely not
Remingtons fault that the magistrate was not motivated to locate them.
11
That sad fact and ignorant set of circumstances was fully admitted to by the magistrate in his
12
orders, but yet he refused go back and reconsider anything or to admit any error himself. Although
13
the whole situation was very blatantly obvious, the magistrate was very bullheaded and decided that
14
it was too late for him to go back and see that it was his error not Remingtons, just to remedy a little
15 injustice and to properly adjudicate this case.
16 All the fully sworn responsive information from Remington was there and properly indexed,
17 and even double indexed, but the magistrate just could not find it. That was the magistrates fault not
18 Remingtons. Yes, Remingtons responsive summary judgment opposition was about 250+ pages,
19 but so what? Said Magistrate was never that busy and had plenty of time to spend a couple of
20 minutes understanding Remingtons index and if he couldnt do it any of his clerks could have done
so in seconds. Remington did his job perfectly well and very diligently, however the magistrate was
21
either incompetent or not motivated enough to understand Remingtons documents or to decipher
22
Remington standard legal indexing format, which was perfectly obvious and simple to follow, just as
23
these present documents are paginated and indexed, had someone wanted to do so.
24
Remington had all perfectly proper detailed page and section number indexes, and in fact
25
Remington had three different lengthy and detailed indexes for only one less than 300-page
26 declaration.
27 However the magistrate found almost nothing Remington wrote because he was looking for
28 page numbers were Remington had cited section numbers, but obviously the two were different and
there were only a quarter to a third as many section numbers as there were page numbers.
718
None of that should have been unclear and obviously the magistrate was not looking very
1
hard for Remingtons answers, which was partly because he gave Remington no credit for honesty or
2
expertise, although Remington had not been examined for either. Apparently the magistrates Santa
3
Cruz University education did not prepare him in any of the scientific disciplines that are needed in
4
this case, or properly prepare him in the advanced disciplines of the most fundamental writing
5 indexing basics.
6 Gans, of course, fully understood the injustice involved here and he and only he
7 understood that Remington had properly responded to every one of his separate statements of
8 undisputed facts, and that the magistrate stupidly missed all of Remingtons answers, and then even
9 after said magistrate acknowledged that he was having trouble finding Remingtons answers and did
10 not understand why that was, he still would not reconsider anything.
To Remington, admitting an error and then refusing to reconsider it was unacceptable for any
11
judge and certainly was so in this case. Remington still gets furious at recalling this injustice!
12
Remington attempted three different reconsiderations to solve that material error, however
13
they were all rejected, without any reasons cited. Gans could have done the honest thing and
14
explained what had occurred, but doing the right thing never occurred to Gans. Gans can still
15 do the truthful thing now that an honest California advocate would be expected to do and certainly
16 in his deposition Remington will structure some questions in this area to prove that Gans is corrupt
17 and has no intention of ever doing the right thing with respect to Remington, now or ever and until
18 after his RICO enterprise has won a total victory. During that period around April 2012, Remington
19 even had one severe case of pneumonia which debilitated him for at least a month, and hampered is
20 reconsideration efforts and attempts to explain that the magistrate had made the administrative errors
and not Remington. Gans could have clarified things and explained that he understood Remingtons
21
documents perfectly, and there were a bunch of other things he could have said, but he never said
22
anything on that issue, but a few weeks later when Remington filed his notice of appeal Gans took
23
on a whole new deceitful strategy of claiming that Remingtons appeal was not timely due to a
24
bunch of technical BS which Remington immediately saw through as did the magistrate, so Gans
25
fraudulent efforts to kill Remingtons federal case before he even got a notice of appeal off to the
26 Ninth Circuit appellate court failed miserably.
27 Therefore, instead of Gans doing the right thing in the numerous pre-appeal and brief stages
28 in the Ninth Circuit, back in 2012-13, Gans did nothing and maintained his dishonest and deceitful
posture through the final unjust dismissal of Remingtons entire lawsuit. Now he will get a chance to
719
explain what he was thinking while he did that. Gans has won some victories here and there but he
1
always fights dirty and never has any ethics about anything that he has ever done in these cases.
2
53. Gans has a duty to the law to be truthful occasionally. Under the law and shackles of
3
California attorney ethics, as cited at #14 above, see Vega and Cicone, Supra, since Gans chose to
4
speak at all, he thereafter has or HAD the duty as an attorney to speak the truth, but clearly he
5 cant, wont and almost never does because his entire defense depends entirely upon frauds against
6 Remington, the courts and any jury that gets involved.
7 That is not likely to work or fly very well when Remington is interrogating him under oath
8 on all of these issues one by one until we get some answers, motives and actual admissions of
9 wrongdoing.
10 Probably this court has learned that looking in to the eyes of a litigant at oral argument
can potentially tell whether the speaker is lying or not, or at leastIf he appears to be earnestly telling
11
the truth as he understands it without obvious deception, excessive anxieties or equivocation.
12
Although looking into ones eyes to see their soul was discredited in the Bush-Putin days,
13
nevertheless, theres something to that concept. Carefully watching the eyes of television pundits for
14
example usually demonstrates that they at least think theyre telling the truth, or perhaps not. THE
15 POINT?
16 Remington is alleging herein that since Gans seldom tells the truth for very long about
17 anything, and if the court stares intently in his eyes and closely watches his demeanor when any
18 of these allegations herein are discussed, Remington alleges that significant material
19 information and inferences of deception will be obtained. Not conclusive perhaps, because
20 Gans is a skilled psychopathic liar on many of these topics, but on the other hand, if the court
catches him off-guard with unexpected questions, Gans could crumble.
21
Gans is just a small-time country lawyer who now has to be experiencing considerable
22
anxiety, because he above all else knows that his career now rests on a flimsy house of cards, and
23
now extends from a very inexperienced human pyramid now 3-4 levels high.
24
That pyramid is founded on deceit, deception, misrepresentations and perjury
25
purveyed through about 20 independent witnesses, and as such, it will inevitably fall
26 eventually, as though it were built in the middle of a swamp.
27 Since about half of those witnesses are essentially unmotivated, unsophisticated and unskilled
28 NON-psychopathic liars, Gans has a lot to worry about, even from, and probably especially from
members of his own firm who are not fully on-board with being involved in a RICO enterprise, or
720
fully knowledgeable about the depth, breadth and severity of Gans corruption, especially as
1
exponentially escalated in 2016.
2
54. Remington did not prosecute the federal case CV 094547 NJV very diligently for a
3
variety of frequently expressed reasons.
4
As Remington has frequently explained and Gans knows all too well, Remington did not
5 prosecute the federal case diligently, if at all, nor was there any reason to do so at the time because
6 the STATE system was fully on track in August 2011 to resolve all of these Mathsons versus
7 Remington litigations, and was functioning normally at that time. That was especially true, after
8 Gans disarmed Remington in August, 2011 with an apparently fraudulent but substantial settlement
9 attempt, which when Remington began focusing on the details of that, it was quickly revoked
10 entirely. Meanwhile, for about two weeks Gans had tricked Remington into believing the cases were
eminently close to settling and so he did not worry especially about the federal case. After the
11
apparent imminent state case settlement, Remington was left to confront an apparently unimportant
12
federal case, which then appeared to be moot, so Remington did not take it as seriously as he should
13
have. However, it as a simple matter of summary judgment law, mentioned in numerous cases, that if
14
a plaintiff does not prosecute the case fully for whatever reason then that should be taken into
15 consideration as to whether such a summary judgment decision was truly on the merits, especially
16 as far as collateral estoppel is concerned in a parallel case where Remington had focused his
17 entire attention during summer 2011.
18 It is obviously ironic and gravely unjust when a litigant focuses on the one parallel
19 (state) case which has very nearly been settled only to have that settlement offer revoked (here by
20 the tricky and corrupt Gans), and then having said case that was 99% settled dismissed via collateral
estoppel based on the first (federal) case that was not prosecuted fully because it appeared to be
21
moot, unimportant and in which no discovery had ever been done by either side. This is a very
22
important point, for this court to consider and if it is not artfully articulated above, there will
23
probably be many other opportunities to do so.
24
However, all of that deception, confusion and smoke, was apparently, in retrospect, part of
25
Gans super-clever, tricky and corrupt master plan, wherein he quickly used that frivolous near-
26 settlement of the state case to fraudulently obtain federal summary judgment in the federal case
27 which Remington did not prosecute, and then several years later in 2014-16 Gans worked on and
28

721
obtained the equally erroneous and corrupt55, in Remingtons opinion, collateral estoppel summary
1
judgment in the state case. Remingtons arguments there against MIL #20 are too lengthy and
2
irrelevant to discuss here.
3
Additionally, Gans corrupt deception over this issue was not fully understood until recently,
4
but it cannot be coincidental that within a mere days of Gans lowball but near state case settlement
5 which made Remington hopeful that the parties could come to terms, Gans filed an unexpected
6 summary judgment motion which had not been properly noticed with required, under three different
7 levels of federal law,meet and confer negotiations. In other words, while Gans was pretending to
8 offer a state settlement which caused Remington to briefly lower his guard, exactly
9 simultaneously with that feigned settlement, Gans Mitchell associates and clerical staff were just
10 finishing-up the final drafts of their comprehensive and frivolous federal summary judgment motion,
which took Remington totally off guard, allowed a totally insufficient time to respond under the
11
federal system, and eventually easily prevailed, but only because the magistrate had been totally
12
biased against Remington by the prior year of Gans derision of Remington and questioning of his
13
testing, veracity, his experts integrity, and everything else about Remington and his case. The
14
magistrate by that time believed every single deceptive and criminal sentence that Gans said or
15 wrote, and Remington was totally powerless to alter that bias for the next year.
16
17 55. EPILOGUE. Miscellaneous final thoughts, conclusions, review of several important RICO
18 principles and elements added-in from the hundreds of pages of notes and cases, which may not have
19 made it into the main document draft in the proper places, dated March 26, 2017. None of the
20 following facts and issues of importance to both this court and to Remington are actually new, and
all could be consolidated into the next draft of this RICO statement where they rightfully belong.
21
22
55
Considerable discovery is now needed in this specific area as alluded to herein; however, it should be noted that quite
23 strangely Judge Reinholtsen twice at five year intervals DENIED Gans persistent and repetitive collateral estoppel
summary judgment requests in the state case and insisted that Remingtons contamination case be allowed to go to trial.
24 That position was reasserted and apparently estopped for about six years by Judge Reinholtsens consistent decisions,
and Remington certainly reasonably relied upon it; but, then one surprising day said Judge abruptly reversed himself for
25 no stated reason and ruled the opposite way. He has freely admitted all along that maybe he is wrong and Remington
certainly believes that the relevant law proves that he is wrong, very wrong, on a variety of grounds, which Remington
26 has researched, cited and written at length about. Remington does not yet have any proof, but the persistent and
ominous inference all along has been that some sort of improper influence, bias or possibly corrupt collusion between
27 the court and Brisso with respect to future part-time employment, when or if this court is dismissed on the pending
corruption charges or is allowed to retire gracefully. In either case, said court will need some sort of part-time legal
28 activity to occupy itself and returning to the office next to his friend Paul Brisso seems like a very logical move. Since
no one is admitting that now, Remington and this court will just need to watch what happens for the next several years,
because federal discovery may not be able to breach that confidence or collusion if it in fact exists at all.
722
A. The RICO enterprises intent is crucial here in all of their fraudulent writings and emails
1
and many of them were deliberately intended as threats to cause fear in Remington. In other words,
2
in the overall context of this lawsuit and the prior 10-year record and background thereof, clearly
3
Gans RICO protection-racketeering enterprise which operated almost exclusively by various frauds,
4
coercion, intimidation and extortion techniques, was in its most basic form an offer to protect
5 Remington from John Mathson and the other soldiers in exchange for Remington giving up his land
6 and dropping all of his lawsuits.
7 By instituting a continuous daily extortive reign of terror, as described, Gans believed that
8 Remington would eventually crack and give up all land and litigations to end their torture and end
9 his enormous, apparently endless financial bleeding, an emotional stress and suffering, before it all
10 became terminal.
However, Gans has been wrong in these cases more than a majority of the time, and here he
11
has very grossly underestimated Remingtons will, motivation and capacity to carry these cases
12
to their logical conclusion, or die during the process.
13
In any case, Gans RICO enterprises clear INTENT is now to completely destroy
14
Remington using whatever means it now may take, and since their civil measures have failed
15 in their initial 10-year test, we can now expect them to turn to deeper reliance upon more
16 drastic and violent criminal measures, to see if they will work any better. Remington is
17 counting on that and assumes that his surveillance systems will capture additional relevant
18 evidence, which will be of use to Remington or other prosecutors here in the future.
19 B. Directness. Direct causation of injury to Remington and his business property primarily
20 owned by the Burl Tree, by the specific criminal acts of the RICO extorting enterprise must be
specifically proven crime by crime and RICO defendant by RICO defendant. After that has been
21
done, the general collusive conspiracy among all of the members traced back to its central
22
leadership and command hierarchy with all of its central offices in the Mitchell firm will follow, and
23
at some point Gans criminal house of cards will topple, and many of the cards will land in
24
deleterious places and positions.
25
Each individual predicate act alleged above is directly damaged Remington and the Burl Tree as
26 adequately specified in detail above, but which will be much further developed after exhaustive
27 discovery in these cases and at which time this RICO statement will be amended and hopefully
28 condensed somewhat, with this document remaining as the basic reference document concerning the
alleged RICO enterprises defendants, near defendants, associates and other suspects, and their
723
specific predicate acts which damaged Remington and his business, to the extent that said predicate
1
acts are known with no discovery yet in this case. Remington has truthfully alleged above that he
2
believes there are another 1-2 dozen legitimate examples of the enterprises mail and wire frauds
3
presently existing in Remingtons disorganized files, presently scattered about in about 100 piles
4
over an area of about 1000 ft. After this document has been filed and a few other matters have been
5 addressed, Remington will begin more serious investigatory activity which will involve the
6 assistance of at least two other people, and hopefully others in the criminal investigatory agencies if
7 their assistance can be enlisted.
8 Each RICO act against each individual defendant must be pled, proven and put-together
9 convincingly enough to convince a judge and then eventually a jury. Remington believes he has met
10 that initial burden and that it is now up to Gans and about a dozen of his top assistants and
racketeering gang members to all get together now and defend themselves under oath and with
11
evidence. This criminal extortion racket has gone on far too long, and now it is up to Gans to
12
convince this court in several contamination case juries that he is trustworthy and honorable and it is
13
Remington that is the lying criminal.
14
Hopefully, Gans will backup his state perjuries 110% and attempt to prove that Mathson and his
15 fellow perjuring witnesses were all telling the truth THEN, and now word is really important in the
16 federal form, and it was Remington that was really lying about it all along, then and now. This time
17 Remington will be ready for all that and he is counting on all sworn state testimony and declarations
18 being reiterated and emphasized here in the federal forum where they will subject their false authors
19 to imprisonment, and most especially their master chief drafters, fiction and perjury writers Gans and
20 Plotz.
C. Remington has adequately and exhaustively alleged willfulness, intent and knowledge by
21
all enterprise members at all levels of their crimes against Remington and what the ramifications
22
and objectives of those specific crimes were intended to be. Conspiracy and fraud are also intrinsic
23
to most of Remingtons allegations above, and strong and unmistakable malice and plenty of hate
24
(and also envy and jealousy) have also been adequately demonstrated and proven in the more than
25
110 major acts of violence and property destruction committed against Remingtons property over
26 the last several years. Remington now has enough still photographic and many hours of surveillance
27 video now to incriminate and convict John Mathson and some of his associates in their overriding
28 extortive terror against Remingtons property exerted daily as the background to Gans litigations,

724
and the enterprises efforts to cause Remington to just give everything up because he cant take it
1
anymore, already alluded to above.
2
D. The RICO literature is exhaustive and includes hundreds or thousands of facts and details
3
which are relevant here, for example: meritless litigation in itself is not extortion, but where it was
4
intended by Gans to break Remington here in as many ways as possible, and as discussed above,
5 and where it was specifically combined with the above combined fraudulent contamination defenses,
6 attacks on Remington and his experts credibility and integrity, but mostly when combined with John
7 Mathsons (with some assistance from Joy Mathson and their associated Westgate gang) continuous
8 daily massive costly vandalisms, property destruction invasions of his property with dangerous
9 beasts capable of killing his grandchildren, the constant circling of his property muttering epithets
10 under his breath, the lying in wait lurching out from behind dark hideouts with flash cameras and
yelling, or worse, ETC all cumulatively, and in combination with said above obviously frivolous and
11
meritless litigation, which never had any settlement value at all until Farmers realize that they could
12
save themselves several hundred thousand dollars by bribing John Mathson to end their super
13
frivolous case DR 080669, Gans RICO enterprise WAS and still IS an overall extortive protection
14
racket against Remington, when it is properly understood.
15 E. For extortion to be an actionable federal predicate act it must be a true and believable
16 threat. Gans RICO enterprises threats were actual, beyond just believable, because at least every
17 other day John Mathson and his gang of Local Westgate hoodlums, plus a few others like Skillings
18 who lives a mile away, came-in and bullied Remington just as though it was a shakedown on a city
19 street corner for Remingtons lunch money. In other words, destroying Remingtons fences almost
20 every day and then walking the perimeter of the property taking pictures, swearing at Remington,
and making sure that Remington was suitably upset is not just a believable threat, but was actual
21
real coercion, real destruction of property which caused real monetary losses and property of all
22
types, especially replacing rare and valuable plants worth from 10-$100 each typically. At the next
23
trial, Remington will provide numerous photographs which show specific damages in specific places
24
all over his large property.
25
Maybe this extortion is clear to the court and to other readers, but by way of analogy again: if
26 someone comes into your house and wrecks, damages and steals several hundred dollars of your
27 property and furniture every day while you are at work, then the extortion is real. It is not just a true
28 or believable threat but it is an actual costly reality which damages valuable and essential
property which is costly to replace, and also causes numerous other emotional, psychological, anger
725
and anxiety damages, where rather soon, the fear and anxiety about what will be damaged or
1
destroyed on any given day can eventually become overwhelming and block out most positive
2
thoughts, during the middle of the night when you wake up worrying, or anytime that you are
3
relaxing away from the property, and also at any time that you are working on the property.
4
In the latter case, it is very exasperating to say the least when just as you are ready to end work
5 for the day in twilight, and come back into the house, you find that Mathson has let -in four (4) big
6 deer, and probably a lot more than that, into your property which are each intent on destroying
7 several hundred dollars of your best roses and rarest Japanese Maples during the night, so you have
8 to call-up the owner of the guard dogs and try to get him in that night or the next day all of which
9 takes time, money and is very annoying overall, especially when it happens every two or three days.
10 Dylan is Remingtons main dog guy right now and has two good deer chasing dogs which
jump off the back of Dylans truck and begin the chase before we can even get back into the gate,
11
and they do it just as well in the dark is in the daylight and the average chase lately is only taken
12
about one minute, but overall requires a minimum of about 30 minutes with the other associated
13
tasks and repairing the holes etc. Generally the holes are sought and repaired before the dogs even
14
get here to keep other deer, bear, foxes etc. from entering through the Mathson cut fence holes.
15 F. As explained completely above, the most fundamental purpose of Gans RICO enterprise was
16 to break Remington financially by increasing his litigation costs over many many years and
17 especially by taking his thousands of hours away from productive Burl Tree business activities, until
18 he went into bankruptcy or otherwise ran out of money. There may have been other ways to force
19 Remington to end his litigations and allow defendants to keep the property that they had stolen from
20 them, however Gans has realized for several years that breaking Remington completely financially
and the several related ramifications of that, and factors which would facilitate that result, which
21
would force Remington to end his pursuit of justice here, was the cleanest, simplest and most
22
probably effective manner of reaching the RICO enterprises objectives.
23
However, breaking Remington financially is a two-way street even for a nasty and ruthless
24
billionaire Corporation. Gans RICO enterprise and especially Linda Lawrence also have gigantic
25
costs which are also increasing, with no end in sight. Even though that top RICO leadership might be
26 prepared to battle Remington indefinitely, presumably there are older, wiser and more reasonable
27 management within Lawrences management hierarchy that will eventually say enough is enough.
28 How many thousand dollars of costs are really necessary to resolve a $300 claim?

726
Additionally, at some point the overall hassle to the enterprise of battling Remington endlessly
1
for decades becomes undesirable, major hits to the reputation of the Mitchell firm and any others
2
associated here is also becoming a possibility as are the risks of incurring a multimillion dollar
3
judgment here, whether on the present merits or after Remington is murdered by the enterprise. Is
4
Allied ready to risk that now?
5 G. Gans has employed an extortive RICO racketeering enterprise here since at least 2012 and its
6 precursors before that in order to prevent Remingtons just environmental claims from ever being
7 adjudicated or resolved in the publics interest, with the overall objective of blocking any
8 environmental cleanup. Mathson and RAO both had ample insurance to easily remove the
9 contaminated debris that they deposited here, however, mostly Gans, Lawrence and a few others in
10 top leadership positions have elected to spend many hundreds of thousands of dollars enriching
themselves and their attorneys and experts at the expense of Remington and the surrounding
11
community in all directions.
12
By the time of trial, the injustices described in this paragraph may prove to be the overriding
13
theme of Remingtons prosecution case. Simply put, the RICO enterprise has maliciously and
14
systematically obstructed justice, tampered with all of their witnesses and even some of
15 Remingtons, have used bribery, extortion and even arson as complained of throughout these
16 documents just to avoid cleaning up the mess that the polluters admitted that they dumped here,
17 during the recent 2016 SOL trial.
18 Although perhaps not a cause of action in itself yet, as complained in these documents, after
19 further discovery and after a few years of putting all this evidence together, Remington infers that
20 fundamentally and possibly above all the RICO enterprise is blocking the required environmental
cleanup which Remington believes is likely a crime in itself in this federal system, but will need to
21
advance that argument with more particularity and case precedents in the future. Above all as used
22
above refers to their philosophical position, however thoroughly and unjustly enriching themselves
23
is clearly their first objective, which has been totally fulfilled now for about 10 years.
24
H. Collateral estoppel has been improperly and totally and artfully applied here to DR
25
080678 and Gans enterprise is also attempting to apply it to DR140426 and also to this case, also
26 entirely illogically, improperly and in conflict with all lawful precedents.
27 At least 1000 pages on this topic exist in the state cases especially from 2015 through July 2016
28 and those arguments are not going to be repeated here at this time. Now, Remington makes the
following philosophical observations:
727
1. Although Remington disagrees with any application of collateral estoppel to these cases, even
1
in the worst case scenario for him the summary judgment in federal case CV 094547 NJV could have
2
only applied to DR 080678 which was a case in approximately the same time frame and based upon
3
the approximately the same basically lack of testing and definitive facts.
4
2.What is significant is that collateral estoppel can apply backwards to a similar case with
5 ostensibly contested identical issues or facts) but certainly cannot apply forward forever and a
6 contamination case, especially 5-10 years forward where there are all new damages, continuing
7 changes in all topographical issues, ALL new tests, different defendants and parties and simply put
8 all new facts which are being relied upon.
9 3. In each new success of action case Remington is requesting damages for the prior three years
10 and not for future damages. Therefore whatever damages may have been requested back in 2008-
2011 are entirely different than what is requested today or in any three-year period prior to one of
11
these contamination cases.
12
4. For example, the sorting of the bad stuff by Skillings on his loader which occurred around
13
1998 and thereafter was not even discovered until 2014-15 when a variety of new studies and
14
analyses were done by all different experts from those that were involved in either early state or
15 federal case. Very clearly, when one analyzes and understands these cases, there is an can be no
16 eidetic allergies on any issue whatsoever between 2008 Case DR 080678, CV 094547 NJV or
17 DR140426, or this case 10 years later, where everything on the site scientifically, visually and
18 actually is very different, and 100% different in many respects. That said above sorting is a critically
19 important factor in these cases and has been probably been adequately explained above.
20 5. Another crucial factor is that asbestos was not alleged in either 2008-9 complaint, so that
material cant possibly be collateral estoppel from one case to the other because it was not even
21
properly considered in the federal case in the first place. No evidence was ever admitted regarding
22
asbestos from plaintiff and it was never placed at issue in either of his two early complaints and that
23
was simply because it had not even been discovered yet or until 2010. Even after it was discovered it
24
did not become important until much later. Therefore, logically it was nonsense for Judge
25
Reinholtsen to declare it barred from a case being heard 10 years later when it was never properly
26 introduced or ever put at issue in the first place by any complaint or answer, and even Gans and/or
27 the enterprises precursors false introduction into the federal summary judgment proceedings was
28 done improperly and unlawfully through Mischa Schwartz, who was not properly or timely
designated as a Rule 26 federal expert, and importantly wrote his reports and visited the sites illicitly
728
and months after discovery had closed. Nevertheless Judge Vadas relied upon him extensively in
1
discussing asbestos improperly in his summary judgment order which then again very improperly
2
led to the unjustifiable barring of all asbestos evidence by Judge Reinholtsen 7-8 years later, see
3
Henry v. Clifford, 32 Cal App. 4Th 315, 321 (1995).
4
Evidently, Remington never presented these issues quite clearly enough for Judge Reinholtsen
5 to grasp his position or what was right on this and many other related issues, however this is a
6 crucial issue and will be extremely prominent coming up in this court and Remington will try
7 again to make it clearer in his Opposition to the enterprises imminent dismissal motion here.
8 I. As rather thoroughly described above, Remington has been gravely deceived by Gans for
9 more than 10 years now and by his RICO enterprise for at least the last four (4). Although gradually
10 and slowly Remington has become less nave and now understands that Gans is a criminal and
nothing that he says is ever likely to be truthful, nevertheless, in the past Remington has reasonably
11
relied on many of defendants frauds which have been explained above. Even Judge Reinholtsen has
12
recognized several of them and, For example, allowed Remington to do some more environmental
13
soil tests in January 2011 because Gans had deceived him about defendants stated false and
14
fraudulent intentions of doing exhaustive soil tests on Remingtons land, but then declined to do so
15 when they noticed that Remington was waiting for defendants testing, and not doing quite enough
16 of his own. Although reliance is not necessary to prove a RICO action, here however there have
17 been literally hundreds of significant issues and events and many of them were relied-upon by
18 Remington believing that a California attorney needed to be and would be ethical in their statements
19 and actions. Now, we understand thats a laugh, but it took quite a few years to fully understand
20 that, because Gans is slippery slick and does just enough normal technical steps to distract you and
essentially throw you off the trail that is really just a wolf in grandmothers clothes. Even a wolf in
21
grandmothers clothes can do some nice things, confuse you and disarm you while resting, thinking
22
and mostly plotting to spring and eat you up.
23
Various examples where the RICO enterprise deceived Remington specifically and Remington
24
had some reasonable degree of reliance thereon, including without limitation: The Esko fraudulent
25
report and fantasy witness situation, wherein Remingtons witnesses attest to the fact that he will
26 never appear to swear under perjury to what he did, which was totally illicit and probably based on a
27 bribe involving Brisso, Martel and others as described above; $20,000 bribe the Mathson arranged
28 and blessed by Gans in order to get Harvey Roberts out of these cases for good, as explained;
Gans Severance Motion Oppositions and DR 080669 related arguments blaming Remington for all
729
contamination of both sites here and citing multiple additional perjuring witnesses to back-up that
1
scientific deceit and impossibility, including Randall, Hilfiker and Evans, etc; the Enterprises
2
consistent and continuous threats of major malicious prosecution counterclaims, plus harassment,
3
libel, punitive damages, etc. as described above. Although all of those threats are frivolous and have
4
previously been denied by Judge Reinholtsen in 2015, nevertheless Gans has determined that they
5 have some extortive value and keep Remington worried and afraid, and hopefully ready to withdraw
6 all of his cases and flee from the area if the enterprise just persists with their pressure, threats and
7 real destructive acts showing that they not only mean business, but they intend deadly consequences
8 here eventually. Since Remington is in Pro per, and cannot recover attorneys fees, the RICO
9 enterprise has no downside when they frivolously attack Remington with such above motions which
10 at most could lose them nonexistent attorneys fees, so they keep them up with every single motion.
Remington anticipates countering that imminently however with one or more attorneys to assist
11
with this RICO action and the promise of attorney fees if we are successful, and also has at least one
12
attorney looking to recover attorney fees in DR140426, when we do a special motion there,
13
imminently.
14
J. Pain, suffering and extortion anxiety have been caused by the RICO enterprise and also
15 in the contamination cases by by those different defendants, and where general and various
16 psychological damages would be recoverable under numerous doctrines.
17 The Burl Tree business does not experience pain or suffering and cannot recover such damages
18 under RICO. Also, Remington is not the complaining type, is tough and stoic, can take a lot of
19 physical pain without complaining and he certainly is not fearful or paranoid in any respect. Is
20 used to working alone throughout his career and risks his life almost daily, or certainly used to do so
in his extraordinarily dangerous, life-threatening logging and trucking activities, doing his normal
21
activities all over the north coast.
22
Nevertheless, as was noted above in various sections, Remington does now fear for his life in
23
essence, and at times in recent years and four different reasonable provocations, has taken to actually
24
wearing a bulletproof torso vest, researching other types of related protections including compatible
25
helmets, neck, back and related assess the reason protective wear and also has familiarized himself
26 with pistol and rifle carrying laws in California, which need not be summarized here, and happily,
27 Remingtons grandfather was a national police pistol shooting champion and taught the 7-12-year-
28 old Remington the safe and accurate use of pistols and rifles at a very young age. Also, when he died
Remington inherited his accurate target shooting and beyond gun collection.
730
As to the anxiety and obvious effects of extortion, in order to make a RICO claim only
1
attempted extortion is sufficient to complete all elements of a federal crime. Successfully
2
completing the extortion and receiving the property which is the basis of the threat is not necessary.
3
Similarly, blackmail is a crime even if it is not successful, as is attempted arson, which again in this
4
case was almost successful, but Remingtons valiant life-threatening extinguishing of the fire with a
5 permanent hose mounted inside his entryway save the structure and only resulted in severe burns on
6 his back took at least six months to mostly recover from.
7 K. As has been amply described above, but nevertheless is a pretty interesting topic to a deadly
8 serious student of Gans gradually evolving advocacy practices, it is interesting to note going back
9 to December 2007 and Gans first legal demand letter and attempted extortive settlement offer, even
10 then. Rather than do the right thing in early 2008, Gans settlement involved, simply put: Remington
gets to keep all of the contamination, such as was known at that time, and to leave his fence where it
11
is but had to pay all surveying costs, County lot line adjustment fees, and anything else that Gans
12
added-on there, such as his legal fees, all of which would have cost Remington well over $10,000.
13
Had Gans had the decency to split that cost, based on what was known then in the interests of
14
the parties, probably the dispute could have been ended easily then, but happily it was not because
15 Remington would still have the same massive problems, costs, damages and liabilities of several
16 hundred thousand dollars today, HAD he signed-away his interests then, to a greedy and unpleasant
17 advocate, but not a criminal one at that time, at least in regards to Remington.
18 Gans progressively more desperate transition from unpleasant and hyper-aggressive advocacy
19 into gross unethical behavior and now criminality since at least December 2012 into 2013, has been
20 adequately chronicled above, but if the court is interested in hearing more, or seeing another several
hundred pages on it, Remington could copy that out of his files easily, whereas virtually everything
21
written in these 1200 or more pages is not copied and is original writing coming from Remingtons
22
memory and quite a few written records. Therefore, in that regard if Remington were asked to
23
certify all of these documents under penalty of perjury and also swear that if called upon he could
24
and would competently testify about anything that has been written in any of these documents, he
25
could and would do so. Obviously he might have to do another clear-headed total proofreading of all
26 of these documents all at once, without deadlines, implied or otherwise, and all over perhaps a one
27 week period where these long documents were not continuously crashing or threatening to do so
28 many times each page, and where he could make everything here consistent, which it cannot be

731
when written over more than six months of changing facts, new research, new cases, new tests and
1
data and frequently changed perspectives, based on the former.
2
L. Heretofore, Remington has not relied on multiple witnesses and prefers to do as much as
3
possible on these cases alone, however during the August 2016 statute of limitations (SOL) trial
4
Remington saw and understood better the importance of having a bunch of ordinary, common
5 -appearing in plain language speaking witnesses backing up your position, even if they dont really
6 know much. Obviously, under the power of a charismatic influence like Hitler or Gans, a bunch of
7 ordinary neighbors with no information whatsoever about the case can become as powerful as the
8 broom splinters in the Sorcerers Apprentice film version by Disney with music by Dukas, which
9 was what Gans managed to do in his fraudulent defense.
10 Therefore, Remington now realizes that he was incorrect in his basic trial strategy and
henceforth will rely on a bunch of other ordinary people to back up his claims as best they can,
11
which would be in addition to his impressive array of expert witnesses in all areas of the case.
12
However now he has people such as Sievert, Dylan, Larry and Larry, several Wilbur neighbors and
13
teenagers and others, who have physically seen Mathson patrolling Remingtons yard, walking into
14
his hedge looking for weaknesses and actually tampering with forces of the fence and especially the
15 gate. Taken in combination with Remingtons very extensive surveillance videos, he expects to be
16 able to nail John and also Joy Mathson to the cross next time and will not really be satisfied now
17 until that has actually happened and both Mathsons have been punished, as well as their leader.
18 Joy Mathson has probably never personally committed a predicate act against Remington, but
19 upon further study it is now obvious that she is the primary facilitator, motivator, aider and abetter of
20 her husbands almost continuous destructive and violent crimes against Remington and his property.
She has been a pivotal figure in this case since 2006 and today is even more so. Therefore, she
21
is at the absolute top of Remingtons deposition list, and well start the motions to compel and
22
protective orders right there.
23
M. Probably it has been adequately covered above, however Remington has gradually become a
24
little too old to remember in detail all of what he wrote last October or even in mid-November 2016.
25
Therefore, he takes these last few pages, which are not a summary or conclusion but are just
26 additional information that is relevant here, to reemphasize the real damages and dangers here that
27 are caused by this RICO enterprise to Remington, his family, to all of his neighbors and visitors to
28 his property, and mostly to his business, the Burl Tree.

732
Remington has more than 3 acres of spectacular gigantic irrigated gardens under several
1
hundred large to very large redwoods with ages of several hundred years old in many cases, and that
2
entire property has now been damaged, destroyed, terrorized and/or greatly reduced in value, beauty
3
and pleasure derived therefrom. Much of that was well documented in the several complaints and
4
even more so in the state cases and their amended complaints.
5 More concisely put here, and without limitation, Remington now complains in general that:
6 Mathsons dumped contaminated and hazardous debris contains a myriad of poisonous dusts, which
7 chemical compositions have been cited above; defendants have essentially poisoned the pristine air
8 formerly here, generally with their invisible sub- microscopic chrysotile and related other asbestos
9 particles, which now float all over the property and neighborhood according to the prevailing winds.
10 As complained above, the cumulative effect of the various airborne toxins cause Remington
uncontrollable coughing at odd times, sometimes when he is 200 feet away from the main asbestos
11
concentrations, and other times not until he is using the major paths that go along the edge of that
12
area that pass within 10 to 30 feet of large asbestos concentrations, mostly of which are partially
13
buried; additionally, there are always putrid smells seeping off of Mathsons Hillside from his
14
unpermitted backyard septic system which was denied because the ground there does not perk
15 properly; there are many unpleasant sounds coming from the Mathsons property, such as said
16 contaminated water flowing-off the very steep mountain, plus numerous other offensive Mathson
17 sounds including his large pack of obnoxious constantly barking little dogs, and his riding
18 lawnmower which takes him several hours each week just to mow his gigantic lawns above, built on
19 top of his huge toxic residential hazardous landfill.
20 Other real dangers and nuisances caused by Mathson in the RICO enterprise include: John
Mathsons constant peeping, like a peeping Tom which bothered and scared Remingtons wife
21
enough for she has not been back here in several years since the last time Mathson lurched his head
22
out of his primary hinged secret door in his upper fence, to see who Remington was talking to, and
23
the photograph it if necessary; in that regard Mathson spends most days, all day while Remington is
24
working during daylight lying in wait behind various concealed hunter -like blinds, with this flash
25 camera and quite possibly his rifle always at the ready; additionally, has complained, Madison let so
26 many potentially violent animals in here including deer with huge sets of antlers, many many Bear
27 and also just the large does who protect their baby fawns and when startled they run around through
28 Remingtons gardens at up to 30 mph trampling anything that might be in their way. Various
grandchildren have been startled or scared by some of that above behavior, but in recent years we
733
just keep them away from the gardens after they have picked a few roses, and go straight into the
1
house to play, because it is just too dangerous outside here. That is very sad, because Remington has
2
undoubtably the most spectacular and beautiful gardens under large redwood trees existing anywhere
3
in Northern California and probably anywhere else.
4
Mathsons constant circling of Remingtons fences, hedges and gate muttering threats about
5 killing (me), scaring Figas and always threatening more arsons if Remington ever looks at them
6 with any hostility or were to unwisely give them the finger or anything of that type. Remington
7 does nothing and always just ignores him and his associates completely without a word, and without
8 any stares or hostility radiated.
9 N. It should be apparent from the above detailed discussions, Gans RICO enterprise has
10 caused serious financial losses to Remington and the Burl Tree property of all types which are
named above, destroying Remingtons present business prospects, and ability to cut any burls;
11
destroying Remingtons ability to show retail or wholesale customers around his Burl inventory, or
12
to conduct any viable burl cutting, finishing, drying, storing or stacking operations. Additionally, as
13
explained defendants have destroyed or than $100,000 of valuable rare plants and roses which
14
eventually were projected for sale as they grow too large and in many cases put out runners and
15 multiply. Remington spent a large amount of money on at least 30,000 rare non-native plants
16 originally, and has had the intent to sell some of them as they mature all along. That is still possible,
17 however huge losses are now being taken. In other words, as explained in detail above, Gans RICO
18 enterprise interferes with all present, future and perspective business relations which Remington has
19 or anticipated, and those losses have seriously undermined Remingtons financial stability and his
20 businesses viability with present damages and estimated future damages estimated above in various
different sections.
21
O. Give land and stop torment. As has been sufficiently outlined above and specified in detail
22
also, Gans basic premise and modus operandi has been concisely condensed in recent years and was
23
summarized twice clearly by Gans directly to Remington during 2016: the first time on the telephone
24
and the second time in the courthouse corridors during a hearing break. Simply put, he offered the
25
following extortive quid pro quo: End your case and we will end your torture. The micro-
26 recorded version, for impeachment, of one of those conversations, of course used more circumspect
27 language.
28

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P. Gans basic RICO strategy involves acquisition of Remington property, and is in effect
1
acquisitive, as used in Monterey Plaza v. Local 483, 215 F. 3d 923 (Ninth circuit 2000), at
2
paragraph 10.
3
Further in that same case that paragraph 17, collateral estoppel is relevantly defined as pertinent
4
here as barring the relitigation of all events occurred prior to entry of judgment in our federal case
5 here, and not just those occurring before the complaint was filed. As alluded to above, Remington
6 construes that case and others as meaning that is successive action complaints are all for new injuries
7 with all new facts and in effect a new primary right generated during each successive year.
8 As applicable to a possible future state RICO case, no possible RICO case or facts were known
9 in 2008, 2009 or until about 2012. Therefore, it would be appropriate to put a RICO cause of action
10 into DR140426 because during that three year period, prior to 2015 some of these RICO facts were
emerging enough to where they could possibly be included now, even if not fully revealed or
11
understood at all until 2016.
12
Q. John Mathson violated PC 519 (1). We will prove that by using a vast array of
13
circumstantial and direct evidence plus numerous witnesses. Hopefully, Joy Mathson will fully back
14
her husband, deny all, claim that Remington is lying and that John Mathson never touched,
15 sabotaged, or broke-through, etc., Remingtons fence ever, for any reason and will thereafter go
16 down with the RICO ship also.
17 John Mathsons violation was simply to do an unlawful injury to the person or property of the
18 individual threatened, which here as we have explained was Remington, his family and business.
19 R. The facts prove Remingtons RICO claim. By this time, it should be perfectly obvious
20 that Remington can easily prove his RICO and environmental contamination claims under the exact
facts which have been fully set forth above.
21
Those facts will no doubt be augmented, refined and in some cases changed to reflect the
22
discovered realities, but Remington believes in following the truth and in any event will not lie or
23
misrepresent what the facts eventually show. Maybe Remington is just too old-fashioned to get with
24
the present trends of false facts, fake news and generally lying about anything which is
25
convenient, or at least appears to be in the short run. Remington does not have the good memory that
26 Gans has and could not possibly keep up with the deceptive webs, strange meanings and twists put
27 to the known scientific facts to formulate his frivolous defense. Under a smart, clever well-prepared
28 cross-examination Remington very much doubts that Gans will be able to do so either, as his facts,
hundreds of false misleading and deliberately deceptive statements and writings have become far too
735
weird to be supported during a sworn deposition or on a witness stand, but maybe Gans will surprise
1
Remington, but thats very doubtful. Gans is smart, sneaky, deceptive and corrupt but he would need
2
a photographic memory to keep up with all of his deceptive and disingenuous motion statements for
3
the last nine years. Ironically, during the hearing in June 2016 Gans made that exact claim to
4
Remington over some document saying in effect, we will eventually verify on the transcript: I
5 know that is true because I have a photographic memory. He went on to botch-up the facts that
6 even Remington had memorized with his old 75-year-old memory; then, over the next 10 days or so
7 Remington recalls laughing and scoffing at Gans, sitting 6-feet away at the same table on at least
8 three occasions, when Gans made especially stupid mistakes of recall, saying I thought you had
9 the photographic memory!, which he obviously does not, and at some point court court got
10 irritated with Remington for scorning Gans that way several different times. Remington had initially
believed that maybe Gans did have a good memory, but the court obviously knew better, and must
11
have thought that Gans was kidding when he said it the first time. Remington being the gullible
12
person that he is, did initially believe that maybe Gans did have an excellent memory, but never
13
showed-it-off much, however sitting next to Gans during various continuous discussions, basically
14
just between him the court and Remington, for more than 110-straight days for about three hours
15 each session, Remington eventually learned that Gans is not all that smart and relies on his young
16 apprentice Plotz to do most of his research, and probably McBride does the rest of it. Clearly the
17 photographic memory thing is a lazy defense mechanism that he uses whatever he does not have
18 proof and is uncertain of his recall of some less than crucial fact, that he assumes Remington will not
19 be able to refute, so blurts out some false fact, and then proves it with that statement, which is very
20 easy to refute when you have the correct dated document in your hands.
All that does is go back to the statement Remington made 50-100 pages ago which simply put
21
was: dont believe anything that Gans says about anything lessee presents actual authentic
22
documentary proof and also swears to that fact under penalty of perjury. That latter act is significant,
23
because whatever Gans swears under penalty of perjury and often knows that he is actually wrong
24
about something, then he is very careful and very rarely commits direct false perjury, or falsely
25 declares testifies about something, when he knows that there is easily obtainable evidence out there
26 that can sink him with just one lie. Probably any attorney would be similarly cautious, but here since
27 Gans knows that Remington is just waiting to trap them in another liar to provable on the record, he
28 is especially careful, and almost never slips up in a major way. That is until now when he is going to

736
have to testify under oath for 10-20 hours at a deposition guarding no less than 1000 false statements
1
and mischaracterizations. Ultimately he will slip-up and lie about matters which are provable.
2
Therefore, as a result and as predicted above, Gans will fight World War III and IV together to
3
avoid being put under oath at a deposition, and if and when he loses that battle in this court, he is
4
expected to have to capitulate, and attempt to buy Remington off for whatever is possible, because
5 he cannot back-up much of what he has done in the last 10 years, at his deposition, without
6 committing actionable perjury over scores of material case issues.
7 S. Interstate Commerce. Several years ago and within this RICO statute of limitations,
8 Remington paid Gans approximately $1000 in various federal sanction amounts which Remington
9 owed, and he did it in increments of $100 and $200 checks. Gans corrupt ploy this time was to not
10 cash any of those checks and hold them long enough to put them all in at one time so that he would
bounce Remingtons account embarrass him with the federal court, knowing that Remington invests
11
his money and does not keep a lot of cash on hand to back-up thousands of dollars of held checks.
12
The reasons that Gans held the checks is easily inferred, and Remington alleges that among those
13
reasons were attempts to justice, extort Remington and embarrass him at a minimum, and since all of
14
those checks were interstate funds drawn on Massachusetts and Indiana fidelity investment accounts,
15 there is arguably a federal predicate act involved here, which needs to be further developed when we
16 investigate Gans actual intent a little deeper, and McBride is also believed to be involved in that
17 fraudulent, if only a relatively minor one, illicit trick and scheme.
18 T. Volume III of these documents contains some of Remingtons photographs and
19 prepared photographic trial exhibits intended originally for the 2016 state contamination trial
20 which never was held. There was an August 2016 statute of limitations trial which used hundreds of
other photographs and essentially none of these other well-prepared trial exhibits.
21
The exhibits appended here are all important, but the court should be aware that they are just a
22
small fraction of those that Remington has already available many of which could be used in a trial
23
here. Additionally, partly because Remington is a serious professional panoramic photographer he
24
has more than 1 million photographs in is possession, many of which are panoramic groups which
25
may consist of as many as 350 photographs each 23 million pixels and may involve HDR exposures
26 of from 3-6 shots the same composition but with different amounts of light getting to the lens. What
27 is relevant here is that Remington has no less than 10-15,000 photographs of his property, in and
28 around or not very far from the dumping zones, so in effect there is probably nothing Remington
cannot accurately depict in a historical sense with just those 10,000+ photographs, plus his charts
737
and drawings on photographs, which drawings all add significant meaning, property boundaries,
1
captions, dimensions, the location and extent of various types of contaminants that dont areas,
2
simulated 3-D elevations and the names of creeks, streets and other prominent features in some of
3
the photos. Simply put, Remington has a lot of photos, numerous photographic charts and he
4
believes that they are an important part of this case that the court should become familiar with,
5 unless it wants to visit the sites which is also an option, however the photographs show significant
6 and material visually obvious changes and differences on the sites approximately every year for at
7 least 10 years.
8 That concludes Remingtons initial RICO Statement on the date below, however since it is a
9 work in progress, the next revision and notes in support thereof will already be in progress long
10 before the court or anyone else receives this document.
11 I certify that the foregoing is believed to be true and correct.
12
13 Initially dated: January 14, 2019
14
15 REVISION DATE: March 27, 2017.
16
17
18
19 BY: ________________________________________
20 Bruce Remington, owner of The Burl Tree, in pro se
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1 PLAINTIFF REMINGTONS RICO STATEMENT- JANUARY 2017

REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

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I. Generally, Remingtons 1983 claim involves:

REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

REMINGTONS RICO STATEMENT-OCTOBER 2016 THROUGH MARCH 2017.

20 all probability parallel state RICO proceedings.

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