Petition for Writ of Certiorari — Arthur Lopez, Petitioner v. Court of Appeal of California, Second Appellate District, Division Seven, et al.

Supreme Court briefNov 13, 2024

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No. 7.6 ”3^

IN THE

SUPREME COURT OF THE UNITED

STATES ARTHUR LOPEZ - PETITIONER© RIG! N AL

VS.

FILED

NOV 1 3 2024

CALIFORNIA COURT OF APPEALS 2ND

OFFICE OF THE CLERK

SUPREME COURT, U.S.

DISTRICT (ROBERT VALDEZ, REAL PARTY

IN INTEREST) RESPONDENT(S)

ON PETITION FOR A WRIT OF

CERTIORARI TO

California Supreme Court

PETITION FOR WRIT OF CERTIORARI

ARTHUR LOPEZ

P.O. Box 13081

Newport Beach, CA 92658

949.278.7793

RECEIVED

JUN 3 0 2025

OFFICE OF THE CLERK

SUPREME COURT,

RECEIVED

MAY 2 3 2025

OFFICE OF THE CLERK

SUPREME COURT, U.S.

QUESTIONS PRESENTED

1) Should United States Constitution Civil

Rights including 14th Amendment Equal

Protection and Due Process under Law

guarantees be applicable to Civil

Harassment Restraining Orders and

Parental Rights?

2) Should California (Forum State) Statutes

include CA Code of Civil Procedure 527.6

Family Codes 3010, 3020 (a) (b), 7602 be

applied to Male, Catholic Christian, Mexican

Heritage Latino I Hispanic Race Biological

Father on matters related to Visitation,

Phone Contact, Custody and Parental Rights

pertaining to his minor children and civil

harassment restraining orders?

LIST OF PARTIES

[x]

All parties appear in the caption of the

case on the cover page

[ ] All parties do not appear in the caption of the

case on the cover page. All parties to the proceeding

in the court whose judgment is the subject petition

is as follows:

RELATED CASES

Arthur Lopez v. Paul Figueroa U.S.

Supreme Court Case &23A812

Dominique “Jessica” Valdez (sister

of respondent) Superior Court,

County of Los Angeles

#18STFL13965, 24-146

Soledad Echeagaray (cousin of respondent,

clerk of the Superior Court of California,

County of Fresno)

United States v. Andrew Hoang Do (County

of Orange Supervisor of the Board, and

spouse of Cheri Pham, assistant presiding

judge of the Superior Court of CA, County

of Orange) #8;24-CR-00126 JVS)

Arthur Lopez v. Cheryl Lopez Superior

Court of CA, County of Orange #16D001283

Arthur Lopez v. Christopher

Covarrubias, California Supreme Court

#S281348, #S283085, U.S. Supreme

Court #23A810, 24-145

Arthur Lopez v. Kristal Gorospe CA

Supreme Court (S284379 IS284621)

(Superior Court #30-2022-01260361) (U.S.

Supreme Court 24A128 I 24A125)

Arthur Lopez v. Perla Elias - CA

Supreme Court S284384 IS284600, U.S

Supreme 24A126 I 24A127, Superior

Trial Case

30-2022-01260365

TABLE OF CONTENTS

Questions Presented..............................................1

List of Parties and Related Cases....................... 2-4

Index of Appendices............................................... 7-8

Table of Authorities.............................................. 9-15

Opinions Below.................. . ..................................... 16

Jurisdiction................................................................ 17

Constitutional and Statutory Provisions............. 18

Statement of the Case............................................. 19-60

Reasons for Granting the Petition........................ 61-62

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Index to Appendices

Appendix A - California Supreme Court August

20th, 2024 Denial Order Case #S284646

Appendix B - California Court of Appeals, 2nd

District January 11, 2024 Affirmance Order and

Denial of Motion to Augment, Denial of Oral

Motion for Judicial Notice Order(s), Case &B324256

Appendix R - Motions to Augment Record Denied in

Error I Abuse of Discretion by COA

Appendix S - Subpoena (Duces Tecum) Robert

Valdez

Appendix X - Text Messages - Rape Threat -

Violence from Robert Valdez to Arthur

Lopez

Appendix Z - Bicycle Casino and Hotel - Robert

Valdez 16 Invoices (June 23, 2022)

Appendix ZZ - Prostitution - Sex Trafficking -

Child Prostitution Related to Miami - Dominican

Republic Cheryl Lopez

Appendix ZZZ - Sex Trade Associate - Miami Crash

Landing of Commercial Airliner RED Air Flight

203 - June 21, 2022 - Cheryl Lopez (Respondent

Robert Valdez’s Sex Trade Associate) (on tarmac,

several photos and a video of Cheryl Lopez

www .twitter .com/rawsalerts/status/153939117378

1073922)

Appendix 7IKZIL - Andrew Hoang Do (Spouse of

Cheri Pham)

Table of Authorities

1) R.D. v. P.M., 202 Cal. App 4th 181 (Dec. 21,

2011) - The Court of Appeals, 2nd District

held pursuant to California Code of Civil

Procedure, CCP 527.6 Second Restraining

Order was justified given Respondent's

history of harassment and determined its

issuance was not unconstitutionally

impairing defendant’s freedom of speech.

Affirmed.

2) Harris v. Stampolis, 248 Cal. App. 4th 484

(June 24, 2016) - The Court of Appeals, Sixth

Appellate District held pursuant to CCP

527.6 sufficient evidence supported the trial

court’s conclusion that respondent made a

credible threat of violence toward the

principal of the school based on his gestures

and actions on the day of issue such as

placing his hands close to the principal,

raising his voice,pointing and gesturing, and

walking back and forth toward the principal.

2) There was sufficient evidence that

harassment was likely to recur. 3) There was

sufficient evidence that the harassment

caused the principal emotional distress.

3) San Diego Police Dept, v Geoffrey S., 86 Cal.

App 5th 550, December 16, 2022 CA Court of

Appeal, 4th District, Division One held

Hearsay evidence was admissible at a

hearing on a gun violence restraining order

Pen. Code 181.55, subd (1)(2), 181.75 subd.

(a)

broadly authorized admission of any

evidence relevant to show an increased

risk of violence, which hearsay included

testimony as a form of evidence under Evid.

Code 140, 1200, thereby harmonizing the

INRO provisions, with other restraining

order statutes construed to allow hearsay

evidence 2)... convincing evidence under

181.75, subd (b) (1), supported the order

because hearsay evidence about the

restrained person’s mental state were

consistent, corroborated and reliable; order

affirmed.

4) California Code of Civil Procedure

527.6 TITLE 7. OTHER

PROVISIONAL REMEDIES IN CIVIL

ACTIONS

(a)

(1) A person who has suffered

harassment as defined in subdivision (b) may

seek a temporary restraining order and an

order after hearing prohibiting harassment

as provided in this section.

Qj) For purposes of this section, the following

terms have the following meanings: (1)

“Course of conduct” is a pattern of conduct

composed of a series of acts over a period of

time, however short, evidencing a continuity

of purpose, including following or stalking

an individual, making harassing telephone

calls to an individual, or sending harassing

correspondence to an individual by any

means, including, but not limited to, the use

of public or private mails, interoffice mail,

facsimile, or email. Constitutionally

protected activity is not included within the

meaning of “course of conduct.” (2) “Credible

threat of violence” is a knowing and willful

statement or course of conduct that would

place a reasonable person in fear for the

person’s safety or the safety of the person’s

immediate family, and that serves no

legitimate purpose. (3) “Harassment” is

unlawful violence, a credible threat of

violence, or a knowing and willful course of

conduct directed at a specific person that

seriously alarms, annoys, or harasses the

person, and that serves no legitimate

purpose. The course of conduct must be that

which would cause a reasonable person to

suffer substantial emotional distress, and

must actually cause substantial emotional

distress to the petitioner. (4) “Petitioner”

means the person to be protected by the

temporary restraining order and order after

hearing and, if the court grants the petition,

the protected person. (5) “Respondent”

means the person against whom the

temporary restraining order and order after

hearing are sought and, if the petition is

granted, the restrained person. (6)

“Temporary restraining order” and “order

after hearing” mean orders that include any

of the following restraining orders, whether

issued ex parte or after notice and hearing:

(7) “Unlawful violence” is any assault or battery,

or stalking as prohibited in Section 646.9 of the

Penal Code, but does not include lawful acts of

self-defense or defense of others, (c) In the

discretion of the court, on a showing of good cause,

a temporary restraining order or order after

hearing issued under this section may include other

named family or household members....

OPINIONS BELOW

[x] For cases from state courts:

The opinion of the highest state court to review the

merits appears at Appendix A to the petition and is

[x]is unpublished.

The opinion of the California Court of Appeals, 2nd

District court appears at Appendix B to the petition

and is

[x] is unpublished.

JURISDICTION

[x] For cases from state courts:

The date on which the highest state court decided

my case was August 20th, 2024. A copy of that

decision appears at Appendix A.

CONSTITUTIONAL AND STATUTORY

PROVISIONS

United States Constitution 14th Amendment Incl.

Civil Rights

California Code of Civil Procedure, CCP 527.6

California Rules of Court, CRC 5.630

California Family Code, Fam. 6320, 7602, 3010,

3020

STATEMENT OF THE CASE

INTRODUCTION

This appeal case involves serious matters of Life

and Death whereby Respondent has long been

involved in criminality of prostitution sponsoring,

sex trafficking and even at one point the part of

having nearly 100 kilos of ready for distribution

cocaine confiscated from his residence storage

container @ 6117 Woodward Avenue; Maywood,

California where he resided with his mother and

father as landlords and still resides with his wife

Maria and two children. In fact, respondent has

been involved in the sex trade with several

associates including Cherly Lopez (formerly known

as Cheryl Queen.), his brother-in-laws, Paul

Figueroa, and Christopher Covarrubias (see

appendix). On May 12th, 2022, Arthur Lopez

attempted to speak to Respondent @ his residence

about appearing to testify @ a June 13th, 2022

hearing involving custody matters with Cheryl

Lopez who is the Mother of Appellant’s four

children, @ approximately 2:15pm. That same

afternoon, Respondent messaged Appellant

suggesting they meet in East Los Angeles rather

than @ his residence @ 5:30pm. Appellant did not

agree to go to an unknown neighborhood in East

L.A. @ night so then Respondent messaged by text

@ 8pm claiming he was rerouting to Corona despite

Appellant repeatedly asking him to stop texting

Appellant. Unfortunately these pleas did not deter

the Respondent, He continued to send badgering

messages. Hence, on May 14, 2022, Arthur Lopez

personally served Respondent with a subpoena to

appear @ the hearing of June 13, 2022 @

Lamoreaux Justice Center in Orange, CA. The

service was carried out by a third party over 18

years of age named Jose Perez (5600 Rickenbacker

Rd, Bell, CA 90201 - 323 784 6001). This good

Samaritan, who Appellant met @ the Local Catholic

Church, also is disabled and uses a wheelchair to

aid with walking while Petitioner stood a block

away, from the service address 6117 Woodward

Ave, Maywood, corner of Woodward and 61st

Street.

However, Respondent chased behind the process

server and attempted to catch Appellant with

threats of physical harm and violence.

Unfortunately, this was not the end of the

Respondent’s threats, harassment and badgering of

Petitioner, @ 2:46pm Respondent started again,

against Arthur Lopez’s request to stop messaging,

with his badgering texts and again @ 6:16pm and

continued @ 9:17pm (05/14/2022) escalating to the

point of threatening to RAPE Petitioner. See

Exhibit X. The Respondent Robert Valdez

threatened to “Ram his dick up your ass...” See

Appendix X

Respondent also threatened physical violence again

by way of text messages. Respondent displayed

uncontrollable anger and violence toward

Appellant to the point of giving chase despite

Appellant being over 150 yards away from his

residence when he was served with a court issued

subpoena. Moreover, these acts of violence, threats

and harassment are all in itself grounds for the

Civil Restraining Order petitioned repeatedly

pursuant to California Code of Civil Procedure,

CCP 527.6 which reads: (a) (1) “A person who has

suffered harassment as defined in subdivision (b)

may seek a temporary restraining order and an

order after hearing prohibiting harassment as

provided in this section.” (b) (1) “Cause of conduct”

is a pattern of conduct composed of a series of acts

over a period of time, however, short, evidencing a

continuity of purpose, including following or

stalking an individual making harassing telephone

calls to an individual, or sending harassing

correspondence to an individual, or sending, by any

means, including, but not limited to, the use of

public or private mails, interfice mail, locomile or

email. (2) “Credible threat of violence is a knowing

and willful statement on cause of conduct that

would place a reasonable person in fear for the

person’s safety or the safety of the person’s

immediate family, and that serves no legitimate

purpose.” Just the same has transpired here with

Respondent’s persistent acts in writing, verbally,

and physically where Respondent actually chased

Appellant attempting to capture for an altercation

in the presence of witness Jose Perez on

05/14/2022. Furthermore, Respondent has sought

after Appellant’s former wife before the divorce and

even perjured himself® the June 13, 2022 Family

Law Court hearing whereby he claimed to never

have been a guest @ any of the local hotels to his

home, when in fact 16 guests requesting invoices

were obtained from the Bicycle Hotel Casino in Bell

Gardens by way of subpoena reflecting Respondent

as paying guest over 16 nights and not with his

wife Maria - CITED I INCLUDED IN INITIAL

OPENING BRIEF TO THE CA COURT OF

APPEALS“see Volume 1 of Clerk’s transcript”

“Pages 41-69 also see Pgs. 33-35” (“Written Threats

of Rape, May 14th, 2022”) and ALSO SEE

APPENDIX X. ALSO INCLUDED IN OPENING

BRIEF TO THE CA COURT OF APPEALS.

Which is in contradiction to their opinion APPENDIX B. Furthermore, see CCP 527.6

(b) (3) Harassment is unlawful violence, a credible

threat of violence or a knowing and willful course of

conduct directed at a specific person that seriously

alarms, annoys, or harasses the person, and that

serves no legitimate purpose. The course of conduct

must be that which would cause a reasonable person

to suffer substantial emotional distress, and must

actually cause substantial emotional distress to

Petitioner (See Table of Authorities CCP 527.6). Just

the same as in this case, Petitioner I Appellant has

suffered tremendous emotional distress not only for his

concern but also for the safety of his four children who

are in constant danger being surrounded by their

mother’s partners - sex trade associates orchestrated

by this respondent and his other prostitution

sponsoring brother-in-laws to the point of now sex

trafficking their sex trade worker Cheryl Lopez who

was captured on the Tarmac @ Miami International

Airport on June 21, 2022 returning from Prostitution

Haven - CITED BY PETITIONER IN THE INITIAL

OPENING BRIEF TO THE CA COURT OF

APPEALS - “See CT, Vol 1, Pg. 72” Santo Domingo,

Dominican Republic while Respondent had also left

the country to evade service of the Restraining Order CITED BY PETITIONER IN THE INITIAL

OPENING BRIEF TO THE CA COURT OF

APPEALS - “See CT, Vol 1, Pg. 20” documents from

the L.A. Sheriff just one week after appearing @ the

06/13/2022 hearing (See Appendix X) where he and

Cheryl Lopez both committed perjury. Also, please

take judicial notice that Respondent refers to himself

as an officer of the court (see APPENDIX X) since

many of his cohorts throughout the State of California

Superior Court network are involved in these

prostitution staffing schemes. For example, two other

Superior Court County of Orange Clerk of the Courts

are Respondents subject of Civil Restraining Order

Petitioned Cases, (Case #30-2022-01260361 1

#30-2022-01260365- Gorospe I Elias) for their part in

these prostitution / sex trafficking rings and alienating

Petitioner’s children for nearly nine years now. In

addition, the spouse of a convicted Superior Court

Judge Jeffrey Ferguson, County of Orange named

Sheryl also was murdered just two weeks ago on the

same day Petitioner filed a brief with the

corresponding Appellate Court (August 2023).

Furthermore, Respondent’s cousin Soledad

Echeagaray is a clerk of the court in Superior Court of

Fresno County. Furthermore, many many syndicates

involved in Prostitution - sex trafficking operations are

being fueled by these thugs even to the point of

involving Haitian - Caribbean Court clerks in Florida Miami Dade Court involved in cover ups and switching

subpoenas to shield sex traffickers involved in the

crash landing of commercial airliner from RED Air

Flight 203 on June 21, 2022. Respondent has a long

history of crossing state and borders to fuel the

prostitution trade. As such, he must be kept away

from Appellant and his children since his web of

criminals is far reaching even to Orange County and

Appellant’s Catholic Churches of Worship.

Therefore, Arthur Lopez respectfully looks to this

court to reverse the State Appellate I Trial Court's

denials and dismissals and issue the petitioned

restraining orders by way of Writ for as long as the

Federal California Law Statutes Permits (5 years).

The Restraining Orders should include not only

Petitioner but also his minor child - 13 yrs. old.

Concurrently, to the Respondent, who is

self-professed Officer of the Court, the Superior

Court of CA, County of Orange Assistant Presiding

Judge Cheri Pham (see APPENDIX ZZZ)

alongside Orange County Board Supervisor

Andrew Do (1st District) where involved in a

Criminal Investigation by the Federal Bureau of

Investigation., U.S. Department of Justice related

to the embezzling I misappropriation of Federal

COVID-19 Funds in the amount of

$10,000,000.00 leading to the home purchased with

a portion of these funds to be raided in September

of 2024. See Appendix 7IZIZIL. AU of which as served

to deprive Petitioner of not only the restraining

order against Respondent but also maintained an

alienation of Petitioner’s children.

Statement of the Case for Petition for Writ of

Certiorari

Errors of the Courts of Appeals I Supreme Court

Abuse of discretion

1) The appellate courts erred I abused their

discretion by affirming the trial court's

denial of requested restraining order and the

appellate court erred by denying appellant’s

Motion to Augment the record despite

unambiguous facts and oral testimony by

appellant demonstrating clear relevance to

the existing Civil Restraining Order case

and direct connection to the facts disclosed

to the trial court within the restraining

order application(s) and abundant good

cause of the present threat to Petitioner by

the

Respondent and his direct associates all of

which establishes clear authority for the

issuance of the requested restraining order

pursuant to California Code of Civil Procedure,

CCP 527.6 “a person who has suffered

harassment as defined in subdivision (b) may

seek a temporary restraining order and an order

after hearing prohibiting harassment as defined

in this section.” (b) (1) “Course of conduct” is a

pattern of conduct composed of a series of acts

over a period of time, however short, evidencing

a continuity of purpose...” (2) “Credible threat of

violence” is a knowing and willful statement...”

(3) “Harassment is unlawful violence, a credible

threat of violence...” Furthermore, in this case

clear, credible threat of Rape and Physical

Violence was repeatedly made by Respondent

(Robert Valdez) against Petitioner for an

extended period verbally and in writing during

the period described in the application for

restraining order. In fact, thread of several text

messages was (see Appendix X) provided as well

and Respondent’s aggression following personal

service by Third Party for appearance at

hearing on June 13, 2022 against Petitioner was

entirely unprovoked and offered to the Trial

Court in writing and verbalized repeatedly

including during Oral Argument hearing @ the

Court of Appeals on January 4th, 2024 @

1:30pm. Clearly an abuse of discretion has

taken place by both the trial court and the 2nd

District Appellate Court. In fact, following

Petitioner’s testimony during oral arguments

related to California Code of Civil Procedure

CCP 527.6 and Motion for Judicial Notice,

presiding Justice Segal summarized Petitioner’s

testimony as “Thorough.” Petitioner respectfully

requests this Court take Judicial Notice of the

entire contents of oral argument testimony and

.trial testimony recordings. These recordings

demonstrate the abuse of discretion having

denied “Restraining” despite all elements put

forth by CCP 527.6 having been met.

In addition, the Appellate Court erred and

abused their discretion in denying

Petitioner’s Oral Motion for Judicial Notice

since the facts included to augment were

relevant to facts included and disclosed in

the trial court and also was unopposed

since Respondent did not appear.

Furthermore, the court erred in also

denying Appellant’s Motion to Augment.

The record docketed on 12/22/2023 and

which was unopposed. The written motion

is composed of 23 pages and it refers to the

Los Angeles Sheriff Department’s delay

and obstructions related to their

compliance with subpoenas seeking

records pertaining to physical assault by

his former brother-in-law and prostitution

sponsoring associate Christopher

Covarrubias for which a fragmented

records release correspondence dated May

12th and 26th, 2023 was attached along

with statutory authority to augment

record under CA Rules of Court 8.155(a).

Moreover, the Appellate

Court erred on January 1, 2024, Page 7 of

their opinion stating: “Lopez, however,

has not cited any evidence in the clerk’s

transcript (the only record there is), thus

forfeiting the argument on appeal.” (Line

8-10). In fact, Petitioner made reference to

the opening brief - Exhibit A + B.

Appendix B of the Restraining Order

Application. CITED BY PETITIONER

IN THE INITIAL OPENING BRIEF

TO THE CA COURT OF APPEALS. On

Page 8 and 9 of the Opening Brief. Also

Page 11 of Opening Brief. Line 24-26,

refers to the Clerk’s Transcript - Pages

41-69, and Pages 33-35 of Volume 1,

related to Prostitution Influx, and to

written threats from Respondent Valdez

on May 14th, 2022 which was also

reiterated during the oral arguments

hearing of January 4th, 2024.

Furthermore, the Appellate Court Judges

erred in their citation of L.O. v. Kilrain

(2023) 96 Cal. App 5th 616, 629, since this

case refers to failing to cite the record.

However, in this present case, Petitioner did

point the judges to the written threats of

RAPE by Respondent in the Opening Brief

within the Clerk’s Transcript - Volume 1,

Pages 26, 27, 28, 29, 30, 33, 34, 35), 78, 5, 13,

14, 20 all referenced in the opening brief

page(s) 22 Trial Court errors”. Moreover,

Clerk’s Transcript Vol. 1, Pages 6-74 was

also referenced on Page 24 of Opening Brief.

The Opening Brief also includes Appendix

A-1,2,3 of the Restraining Order Petition

reflecting threats of physical assault by

Respondent Valdez on 05/14/2022 (see

APPENDIX X) and it also includes

correspondence from the Los Angeles

County Sheriff related to Christopher

Covarrubias (see Appendix R),

Respondent’s brother-in-law and

Prostitution sponsoring associate who is

cited on Page 8 of brief and Supreme Court

of CA under docket case # S283085 please

take judicial notice of its content along with

2nd brother-in-law Paul Figueroa

prostitution sponsoring associate case

#S283090 all of which is part of the record in

this appellate court and elaborated during

oral argument hearing of January 4, 2024 @

1:30pm.

Moreover, this Supreme Court may take

notice of DKT #24-145 +

24-146. For all these facts, the appellate

court’s errors and abuse of discretion and

the trial court’s errors and abuse of

discretion both having ignored CA Statute

Authority for the issuance of Civil

Restraining Orders, California Code of Civil

Procedure CCP 527.6, this Supreme Court is

Petitioned for Writ of Certiorari Reversal of

both the appellate court’s affirmance and the

trial court’s Denial of Civil Restraining

Order and Moreover with the power vested

in this court petition is also made for

granting of 5 yr. restraining order against

Respondent Robert Valdez, et al in favor of

appellant / petitioner Arthur Lopez (and his

minor child - 13 yrs. old) at such time this

court deems appropriate given the threat

this respondent poses now).

Respectfully submitted,

Arthur Lopez

Date: October 21, 2024

Trial Court Errors

1) The Trial Court erred in denying temporary

restraining order on under this case and the

originating initial restraining order Petition

also known as 225TROO3598. CITED BY

PETITIONER IN THE INITIAL

OPENING BRIEF TO THE CA COURT

OF APPEALS - “See Clerk’s Transcript

Volume 1 Pgs. 5, 13, 14, 20”

2) The Trial Court errored, abused their

discretion by failing to accept violations

pursuant to CCP 527.6 by respondent

including threats to RAPE, physical

violence, sodomize upon appellant by

Respondent. CITED BY PETITIONER IN

THE INITIAL OPENING BRIEF TO THE

CA COURT OF APPEALS - “See CT, Vol 1

pages 33, 34, 35, 26, 27, 28, 29, 30,

78”

3) The Trial Court erred, abused her

discretion by refusing to recognize the

danger Respondent poses to appellant and

his children through the criminal state of

mind whereby no barriers of Law serve to

deter the sex trafficking carries this

Menace to Society has embarked on for over

35 years.

4) The trial court failed to accept recognize the

severity of Respondent’s perjured testimony

of June 13, 2022 and its validation of

prostitution in sediment @ a local hotel to

Respondent’s residence as a rule - The

Invoices provided clearly contradict the

testimony of June 13th, 2022 for which a

complete reporter’s transcript had been

produced for the CA Court of Appeals and

judicial notice should be taken by this court

of its entry to this record at the CA Court of

Appeals through motion to augment record

concurrently. For all these reasons,

petitioner Arthur Lopez humbly petitions

this court to take judicial notice of

concurrent restraining order cases related

to this Respondent’s brother-in-laws, Paul

Figueroa and Christopher Covarrubias 23A810 and 23A812, 24-146 and 24-145,

S281353 and S281333, and S281348 and

S281334. Respectively as support of the

severe threat these criminals pose to

appellant and his family and whereby the

trial court has errored and abused their

discretion a failing to as knowledge these

threats in violation of CCP 527.6 and as

such their erroneous denial and dismissal

should be vacated and writ issued granting

a civil restraining order against respondent

and in favor of Arthur Lopez and his four

children as prayed in the Petitions. CITED

BY PETITIONER IN THE INITIAL

OPENING BRIEF TO THE CA COURT

OF APPEALS - “See CT Vol. 1, Pages 6-74”

Conclusion

For all these this court should reverse the trial

court errors of denial and dismissal of 10/14/2022

and issue requested 5 year restraining order in

favor of Petitioner Arthur Lopez and his minor

child Luke and against Respondent Robert Valdez,

as prayed.

Respectfully submitted,

Arthur Lopez

Date: May 17, 2025

STATEMENT OF FACTS IN SUPPORT OF THE

CA COURT OF APPEALS ERRED DENIED IN

MOTION TO AUGMENT OF AUGUST 2023

Correspondence from the Los Angeles County

Sheriff’s Department relates to the Criminal

Assault by Respondent’s Sex Crimes Associate

Brother-in-Law Christopher Covarrubias upon

victim (B328530 I Supreme Court #24-145) Female

- Dominique Valdez on November 17, 2018 just a

few miles (3.8 miles) from Respondent’s apartment

complex - Residence (where he has lived for more

than thirty years - rent free as landlord). The

assault occurred @ 1863 East 69th Street, Los

Angeles, CA 90001 during a prostitution event

discovered by the victim while still married to

assailant-striking her in the face and neck. He was

arrested and changed. Respondent Robert Valdez

residence 6117 Woodward, Maywood, CA 90270. In

fact, Christopher Covarrubias’s residence was/is

converted into a “Brothel” disguised as an “AirBnB”

next to Superior (on housing) Foods and Numero

Uno Market Warehouses with Long Haul Big Rig

Semi-Trucks ever present. Please note this criminal

is/has been associated with U.S. Air Force and

other rogue participants. In addition to these

relevant facts, in support of lodging these sheriff’s

correspondence, please note the Bicycle Hotel

Casino which produced 16 Registry Invoices for

Robert Valdez who signed.

Robert Valdez (Respondent AKA also Roberto

Valdez) is located @ 888 Bicycle Casino Drive, Bell

Gardens, CA 90201 only 3 miles drive from

Respondent’s apartment complex. These facts are

part of the initial civil harassment restraining

order petition following threats of Rape and Bodily

Harm and the Crash Landing of RED Air Flight

203 @ Miami International Airport June 21st, 2022

existing from prostitution haven Santo Domingo,

Dominican Republic, during which time

Respondent was out of country evading service of

the Restraining Order Notice to appear by the Los

Angeles Sheriff (22STROO3598). Filed June 15th,

2022, and moreover, a female sex trade associate

Cheryl Lopez - (16DOO1283) following a travel ban

hearing on June 13th, 2022 with Respondent

Robert Valdez testifying and committing perjury*

appears to be fleeing the burning plane on the

tarmac in a 39 second video posted by Actualidad

Radio LLC and reposted by Russian Television - RT

News from “@jumpjim”

(www.twitter.com/rawsalerts/status/153939117378

1073922) (see APPENDIX ZZZ). Now if these sex

criminal activities are not enough, then you also

have another associate of the sex trafficking,

respondent’s brother-in-law aka Paul R. Figueroa

(See B3280532) who is not only married to Robert

Valdez’s sister Celina Figueroa who has covered up

these sex crimes for years (at least 15 years) but is

also directly connected to respondent’s

brother-in-law Christopher Covarrubias, and

Cheryl Lopez. Furthermore, Cheryl Lopez who is

employed by an International (South Korea based)

company (as is Paul Figueroa who is employed @

davidplastics, a plastics company operating across

into Mexico and whom is of Puerto Rican descent.)

colluded with Erika Tsimbolav of Ukrainian

Heritage, to falsely accuse Plaintiff I Appellant

Arthur Lopez of wrongdoing leading to a

(09/12/2016 - Superior Court of California, County

of Orange, #16HM10451) 37-day false

imprisonment before a judge was compelled to

dismiss all charges and closing case without a trial

after finding absolutely no evidence of any wrong -

100% exonerated but having to endure captivity -

sleep deprivation and abuse from O.C. Sheriff.

In fact, the motive and scheme by Cheryl Lopez Christopher Covarrubias - Paul Figueroa - Robert

Valdez - Erika Tsimbalov through this false

imprisonment was also to compromise a custody

hearing of Plaintiff’s minor children, which was

supported instantly by bias judge Stepheni Leong,

who was herself arrested on a child endangerment

charge, November 9, 2016 (7pm). In addition,

“Public Defender” failed to file appeal on the

adverse custody matter ruling where Plaintiff was

in custody (coincidentally - or not - 37 days just

beyond the 30 day appeal period), further alarming

Plaintiff and his children (coincidentally or not,

South Korean Heriage - “Kim”).

In summary, the Los Angeles County Sheriff’s

Department has delayed the release of these two

correspondences dated May 12th and May 26th,

2023 needlessly for over a month and under false

pretense and under color of haus since the Calbert

fragmented released facts pertaining to this

criminal assault are very much in the Public

Interest to be released and not subject to

exemption, as they have ultimately acknowledged.

Moreover, more facts and evidence is subject to

release especially since the Los Angeles Sheriff’s

Department and Sheriff Robert Luna have been

repeatedly served with a Civil Subpoena (Duces

Tecum) as of April 13th, 2023. Furthermore, the

Restraining Orders sought are to also protect

Plaintiff I Appellant’s children (2 of which are

minors and the two females are 18 and 20 years

old) very much vulnerable since these predators

wherein described represent themselves as “officers

of the courts” officers of the U.S. Armed Forces,

representatives of Multinational Entities, but he

reals in that they are actively sponsoring sex

crimes, criminal activities, schemes, and more The

facts prove the Public Interest is in unmasking

these criminals, regardless of who they represent

on who is providing shields in sex trafficking -

prostitution is illegal and therefore this exhibit is

requested to be lodged for this court’s

considerations and could not have been introduced

any sooner, but the abusive, criminal sex crimes

contained had been included in the initial filings petition.

I, Arthur Lopez, hereby declare under penalty of

perjury under the laws of the State of California all

herein contained is true.

Respectfully submitted,

Arthur Lopez

October 27, 2024

>• Please note during 05/12/2022 - 05/14/2022

WRITTEN THREATS OF RAPE AND

BODILY HARM (see APPENDIX X)

petitioner repeatedly requested respondent

cease sending messages but he ignored over

a dozen demands to stop harassment -

written threats I messages

>■ Also please note Exhibit C consisting of 16

records from Bicycle Hotel Casino 888

Bicycle Casino Drive, Bell Gardens, CA

90201 - 562.806.4646 confirming Prostitution

- Sex Trafficking Operation despite

Respondent residing a few miles away with

his spouse Maria Valdez and Daughter I Son

@ 6117 Woodward Dr, Maywood, CA 90270 -

562.388.9105 Montors - Fireworks went off

when Petitioner arrived @ Bicycle Hotel

Casino in processes involved of subpoena. In

addition, Monitors Fireworks went off when

Respondent sent text message threats from

his phone May 14th, 2022 - The area Bell I

Maywood is wired by Criminal Organizations

associated with Respondent. Please take

judicial notice of California’s hearsay

exception as past recollection recorded: prior

identification - evidence code 1200 (2.2)

Plaintiff I Petitioner: Arthur Lopez

Defendant I Respondent: Cheryl Lopez

Case Number: 16D001283

• Respondent is and has been in sex trade for

many years. She continues to engage in toxic

sex-relationships locally, domestically and

abroad - the latest prostitution engagement

involves travel to the Dominican Republic

via Santo Domingo through Miami, Florida

return Flight 203 on June 21, 2022 crash

landed on which Respondent was on board

and captured in still pictures and video -

These images of respondent deboarding

while plane was engulfed in flames has been

circulated through major news channels

including ABC, NBC, RT News, and

Actualidad radio and reposted through

Twitter IX accounts including countless

users of which Petitioner is in possession of

copies obtained through the Internet - these

capture Respondent without the three minor

children. Prostitution is illegal in California

where the children and the Respondent

reside and Respondent having committed

perjury by lying to this count is also harm to

Petitioner. The children’s best interest is not

fulfilled by Respondent’s gruesome criminal

activity even if it’s engaged in the

Dominican Republic where children are also

included in their sex crimes I trade. CA

Family Code provides for the children to be

safe and mandated from the elements erred

when Respondent suffers from mental

illness and persists in sex for financial gain

schemes - please note Petitioner’s 2

daughters (17 and 19) have been in

Respondent’s custody since 2016 while she

has been part of sex trade criminality (See

People v. Fowler 818 Cal.

136).

October 27, 2024

Arthur Lopez

Reasons for Granting the Petition

This petition seeking the granting of a 5 year civil

(criminal in the alternative) restraining order

should be granted in the Public Interest to not only

provide protection from Respondent’s further

continued assaults against Petition, which have

included threats in writing of Rape among other

violence, but also shield Petitioner’s Minor child

and three other children.

Moreover, by granting petition U.S. Constitutional

Civil Rights under the Fourteenth Amendment are

restored in this regard @ the State Court level and

as such will also serve to support the significance,

validity, and protection of Parental Rights by the

14th amendment given the urgent need to reunite

minor child and biological father bonds this

professed “officer of the court” unlawfulness has

assisted in separating.

CONCLUSION

For all these this court should reverse the trial

court errors of denial and dismissal of 10/14/2022

and issue requested restraining orders in favor of

appellant and his four children as prayed.

Respectfully submitted,

Arthur Lopez

May 17, 2025

The petition for a writ of certiorari should be

granted.

Respectfully

submitted, Arthur

Lopez

Date: May 17, 2025

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.