1

2 3
4
tr

Cheryl Meril 1"245 California StreeL, Francisco, cA 941-09 San Redacted

4t5-290-1122

#303

,-::r

-'-

n !,: T -

CHERYL

MERII,,

CROSS-DEFENDANT

IN

PRO SE

6
7
B

SUPERIOR COURT OF CALIFORN]A

COUNTY

OF SAN DIEGO CENTRAL D]VIS]ON

CHERYL MERfL,
CROSS - DEFENDANT ,

case No. :- 3rLoo9-0092049-CU-DFCTL

CROSS - DEFENDA}iIT CHERYTJ

10

11
TZ

vs.
EDMOND

DECIARATION

IN RESPONSE TO I,ETTER FROIII GARY A. BEMIS, ESQ.

REQUESTING ECKNOWLEDGEIIENT OR DENIAL OF DEF.AUI,T .TIIDGMENT IN WIIOLE OR PART.

MERII" g

WOLLMANN,

13 L4

CROSS-PLATNTIFF.

Dept:

65

UNL]M]TED
15 16
11

CIVIL

CASE

1B

19 2n
2L

22 23
an

I cheryt Meril, cross-Defendant, hereby submit a Declaration t the court in response to a letter I received from Gary A' Bemis, Esq. (hereby referred to as "Mr. Bemis") dated september 1-1-, 2oL3 behalf of Edmond Wo1lmann, Cross-Pl-aint'iff (hereby referred to as..Mr. Wo1lmann"). (See Exhibit A) In such letter, I am asked to respond if I am disputing Lhe default judgment in fuII or part issued by the court in 201-1 and to respond wit.hin 30 days ' I. Background
As I have stated throughout the case, I was originally contacted, harassed and slandered by someone who convincingly assumed the identity and former email address of Mr' Wollmann' Suc person fed me to believe he was Mr. wollmann by also posting on a
-1TN RESPONSE TO LETTER DECLARATION MERII,'S CROSS-DEFENDAI{T CHERYL OR DENIAL OF ACKNOWLEDGEMENT REQUESTING ESQ. BEMIS, A. FROM GARY DEFAULT .JUDGMENT, ET AL.

25 ?6
2"1

Z6

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

USNET astrology group Mr. Wollmann has overseen for years. slander appeared in search engines and later on a large blog accusing me of being a felon among other vile things. The

The

impersonator was later disclosed to be Hollywood horror movie special effects man Rick Lazzirini (Mr. Lazzirini). Mr. Lazzarini had a former dispute with Wollmann years prior that he obtained his former America On Line (AOL) email address, Ewollmann@aol.com, as one of his own AOL sub-accounts. After a large Motion to Quash was filed by Hollywood entertainment attorney Joe Hart, Esq. on behalf of Mr. Lazzarini who had placed me in a false light to the Court, my case was legally over. Regardless, I wasnt convinced at that time someone other

than Mr. Wollmann had contacted me so I offered a reasonable no money settlement agreement to Randall Dierlam, Esq. I had good

reason to suspect Mr. Wollmanns involvement based on evidence of past public nuisance and trespassing convictions, as well as a blog posted at www.smbtech.com/ed disclosing years of Mr. Wollmanns USENET kook awards, writings and revenge tactics indicating an unstable person unwilling to accept responsibility for his problems that he was the likely perpetrator. Back in 2007, I was immediately threatened with a lawsuit by Mr. Lazzarini having later become an unwilling recipient of his intensely provocative harassment campaign. Mr. Lazzarini was a

complete stranger who had created a fictional account of my threatening the life of a San Francisco Chronicle and S&M Sex Blog writer Violet Blue that he sent an accusatory email disguised in the header as a fan of my jazz singing.
-2-

CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

I sent Mr. Wollmann two cease and desist letters and even offered him One Thousand Dollars ($1,000) to take down a slanderous blog in a vain attempt to divert a lawsuit Mr. Wollmann never responded to. Mr. Wollmann never sent any letter to disclose

someone was impersonating him and later was denoted by a process server avoiding being served. According to Mr. Lazzarini in his Motion to Quash, Mr. Wollmann had lost his AOL email address he had later obtained due to complaints about unlawful mischief. After having witnessed this dispute for many years now, I contend Mr. Wollmann has gone after me with great intensity because he is an occultist and Satanist who, along with his horror film special effects impersonator Lazzarini, is seeking to exercise undue suffering and pain on not only myself, but also my elderly parents. My only sibling died in 2002 of bacterial meningitis. I consider Wollmanns request of the Court in his pro se brief to pierce, i.e., as in piercing ones heart, of my fathers alleged trust is some kind of veiled threat. Such is why I believe

Mr. Wollmann has chosen his attorney Mr. Bemis whose office is in the Riverside of the County where my father owns his home. Mr. Wollmanns collection of a large portion of the judgment he believes he will one day obtain is based on the trigger dates of the death of my father or mother. I therefore view Mr. Wollmann as

someone who is quite willing to have my father murdered to obtain his goal of revenge and financial success in collecting a large portion of this judgment. Normal people work for a living. Id like to once again bring to the Courts attention Mr. Wollmann has continued in a pattern having exhibited a
-3-

CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

preference for contacting me on key dates including Valentines Day and near to my Birthday as a means to terrorize me as he has again with his attorneys letter dated September 11th. I did not perpetrate this dispute that was caused by Rick Lazzarini, owner of The Character Shop in Simi Valley, CA and former horror movie special effects person for the film Night on Elm Street, Alien and others. I was not present in Court back in 2011

to defend myself from Mr. Wollmanns false accusations and omissions of facts due to my being led to believe the case was over by two attorneys who reported back to me as such, including Timothy Walton, Esq. I had contacted Mr. Walton for a witness testimony. Mr. Wollmann feels a need to continually contact me about owing him an extremely large sum of money I clearly do not have. It has

already been fully disclosed through the Court of my owning no real estate. Ive ridden mopeds and eBikes since 1986. I have also been indebted hundreds of thousands of dollars due to an accident last year I had no medical coverage for in which the defendant had only $15,000 insurance policy and no assets. It is therefore quite

revealing that Mr. Wollmann has proceeded with a new attorney to continue to contact me just five (5) months since I traveled to appear in the San Diego Superior Courts jurisdiction. Due to Mr. Wollmanns choice of hiring an attorney in the county where my father lives and owns his home, I believe Leslie Behunin Jrs life is endangered by Mr. Wollmanns belief he has a multi-million dollar trust in which I am imagined as an alleged beneficiary. Mr. Wollmann is mistaken, my father has never been
-4-

wealthy and the cars he has owned have been modest clunkers since CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

his 1950 T-Bird convertible days. Mr. Behunin suffered a stroke in 1992 and has not worked for decades living on social security. I have not heard from Mr. Behunin since I last spoke with and corresponded in 1998 when I designed a web site about his career as a musician. I am unaware of any trust and my father has always been

of modest financial condition having never helped me financially after I left home in 1978. My parents have not been people I could

ever count on in times of need because I was born out of wed-lock that was held against me as a burden to them. I am certain I am not

in either of the parental wills as a beneficiary that they have their own elderly siblings to provide for. My real inheritance is through Jesus Christ whom I have surrendered my life to as my Savior. My true home is in heaven with God. II. Summary of Declaration and Response to Mr. Bemis Request Though I acknowledge the Court allowed a default judgment to be entered against me in 2011, I contest it as being unlawfully unduly influenced by Judge Robert Longstreth who had several unlawful hearings discussing me in length with Mr. Wollmann in ex parte in the East County Superior Court Division in 2009-10. Judge Longstreth later became strongly opposed to me suggesting there were consequences for filing a lawsuit against an innocent man. His discrimination was largely due to my public on-line affiliation at the time with the California Association of Legal Document Assistants, aka CALDA as a Legal Document Assistant under the DBA At Your Service Legal Document Prep.
-5-

and

Judge Longstreth is

strongly opposed to the pro se litigant industry that my former CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

profession supports because it is not lucrative for the legal profession or court system. Judge Longstreth went so far as to donate to the campaign of a candidate who was overseeing the restraining order case I filed in San Francisco, Judge Ulmer. Other reasons I contest and deny this judgment in whole are as follows: 1. Mr. Wollmann intentionally omitted relevant facts in his

testimony at the default judgment hearing. 2. Mr. Wollmann was not damaged by me since there was an

entire website at www.smbtech.com/ed up for many years he was unable to file a lawsuit over because the information was true. 3. Mr. Wollmann did not present any evidence I had affected

his modest income in his part-time astrological consulting business nor sales of a decades old book. The overwhelming fact remains

Mr. Wollmann did not so much as even lose his job as building manager at his Le Mesa apartment complex where he enjoys free rent. 4. Mr. Wollmann did not incur One Hundred Thousand Dollars

($100,000) in legal fees granted by the Court in his having appeared largely in pro se throughout his case with the exception of a short period of representation by Randall Dierlam, Esq. in 2009 who did not file a Summary Judgment. There was no trial. The attorney who

represented Mr. Wollmann at the default judgment hearing did not cause such large legal fees, nor did I ever hear from him. 5. Based on the facts of this case, I clearly did not act in a I

criminal manner though there was a large punitive based judgment. had attempted to settle the dispute in good faith prior to filing a lawsuit and after a deposition hearing in 2009.
-6-

My settlement

CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

offers failed because I was a targeted individual of a psy-op that the perpetrators intended to take all the way. 6. Mr. Wollmanns former negligence of taking care of his on-

line identity issues has been overlooked entirely by the Court as well as Mr. Lazzarinis mischief and unlawful conduct. The fact of Mr. Lazzarinis profession speaks volumes of a psy-op to frighten me into submission of such Satanic occult mischief. 7. I have no amount of money that Mr. Wollmann could lawfully obtain, nor possessions. Five years of financial records were The likely

submitted at the Debtors Hearing five (5) months ago.

purpose for Mr. Wollmans contact is to continue with his pattern of key dates occult based harassment that posed a conflict to the former attorney who since resigned. Mr. Wollmann envisions death. I do not recognize the Courts punitive based default judgment issued against me as lawful that was based on the negligible politics perpetrated by Judge Longstreths undue influence over the Court. Such judgment was in corroboration with an impersonators

dirty evil psy-op to entrap me into some horror film based web of lies in which I was intentionally lured into filing a lawsuit. I hereby declare under PENALTY OF PERJURY under the laws of the State of California the aforementioned statements are true and correct.

CHERYL MERIL CROSS DEFENDANT IN PRO SE Dated: September 16, 2013

-7-

CROSS-DEFENDANT CHERYL MERILS DECLARATION IN RESPONSE TO LETTER FROM GARY A. BEMIS, ESQ. REQUESTING ACKNOWLEDGEMENT OR DENIAL OF DEFAULT JUDGMENT, ET AL.