Brad November 16, 2021 Hand-delivered to Lamoreaux Justice Center

and Sent via Email

Conley Supervising Judge Julie A. Palafox

Superior Court of California
38 Springacre Family Law Operations
Irvine, CA 92614 341 The City Drive
P.O. Box 14710
949 322 0280 Orange, CA 92863-1570
[email protected]
Re: Local Rule 12(e) Complaint against Steve Dragna, Esq., Case No. 18D000296

Dear Judge Palafox,

A. Important facts you know after reviewing the entire case file.

Since you “reviewed the entire electronic legal file,” like Mr. Dragna, you know:

1. As a Whistleblower, dad reported that mom, a UCI Associate Professor of Education,

had highly-inappropriate online relationships with minors, including a romantic and
sexual one with a 17-year-old high school student (while dad cared for children, 24/7).

2. As a mandated reporter, dad reported Child Abuse/Neglect to UC Irvine under CANRA

& UC Systemwide Policy. UC Irvine did not investigate dad’s report. But when CPS
investigated a nurse practitioner’s report about the same matter, it found medical abuse/
neglect of a child by professor-mom.

3. Under penalty of perjury, dad maintains that professor-mom uses her position, title,
income, tenure, and privilege at UC Irvine to abuse him—and deceive the Court.

4. Dad maintains that when he (and witnesses) offered help, professor-mom retaliated by:

a. using UC Irvine to frame dad & falsely accuse him of Domestic Violence;

b. using UCI PD as a personal police force to harass dad;

c. using sympathy for real DV victims—and laws and programs meant to protect
women & children—to advance her fraudulent & selfish desires;

d. using laws and UC policies, especially those regarding tenure and on-campus
housing, to protect her as a tenured professor, fake DV victim; and abuser; and

e. using family court as a crowbar to pry children from their protective parent.

5. As an (inactive) member of the California State Bar (#163711), dad must comply with
the Bar’s ethics rules—just like Mr. Dragna and the other lawyers in our case.

While writing this letter, I wondered, “what would an objective person unfamiliar with our
case think about my Local Rule 12(e) complaint? I concluded that most reasonable people
would ask questions like:

“Within the child lies the fate of the future.” Dr. Maria Montessori
 “A UCI professor? Of education? An online sexual relationship with a high school
student?! False DV charges?! Whistleblower? Retaliation? Those are serious charges—
about a prominent public professional—who deals with children. Is this true?!?!”

I concluded that a reasonable investigator would be curious and ask questions like:

“If mom’s a fake DV victim, should she be allowed to teach at UC Irvine School of
Education? If dad’s a fake Whistleblower, should he be allowed to practice law in
California—and serve on UC Irvine committees & boards? Is dad defaming a real
DV victim? Or is he reporting a predator who neglects her own children—while
telling California parents how they should raise & educate theirs?”

As Supervising Judge, you get to decide something that matters to the People of California,
especially Orange County parents of school-age children. You can shunt my complaint. That’s
what Mr. Dragna has done with CPS reports; UCI Police reports; a 99-page §730 custody
evaluation; and letters from experts, witnesses, and our children. Or you can use my
complaint and your authority to do what the Emergency Investigator strongly recommended:
more investigation. A choice to not investigate—at this point—is a choice to evade the truth.

And I concluded that protective parents would want to know:

“Why did the Supervising Judge refuse to investigate a complaint about minor’s
counsel—even after reviewing the entire electronic legal file—where mom is a
UCI Professor of Education who neglected her own child (CPS report) and violated a
Domestic Violence Restraining Order (UCI PD arrest)?”

“Since mom teaches classes like Adolescent Development at UC Irvine, shouldn’t the
Supervising Judge use her authority to at least look into the merits of dad’s complaint?
Why not? Couldn’t she report him to the California State Bar if he’s lying?

“What does it take to get the Supervising Judge to investigate a Local Rule 12(e)
complaint about minor’s counsel?”

“Is Mr. Dragna or the Court helping UC Irvine cover up a scandal?”

B. Corrected assumptions and suggested questions for Mr. Dragna.

You wrote, “it is clear this is a highly contentious and acrimonious dissolution.” That’s not
correct. While our ongoing dissolution has been heartbreaking, destructive, wasteful, and
expensive—it’s not acrimonious. And although I hate what she’s done to our family, my
acrimony isn’t with our children’s mom (a person I loved who needs psychological help). My
acrimony is with the Court you supervise—and the people, like Mr. Dragna, who’ve used
your Court to take advantage of our family. (Observe that even my abuser, the professor-
mom, is a victim of Mr. Dragna and the family court system.)

For “evidence” that made my acrimony “clear,” you cited:

“almost four years of litigation, four requests for temporary orders, mutual requests for
domestic violence restraining orders, four motions, twenty-nine hearings, an

“Within the child lies the fate of the future.” Dr. Maria Montessori
 emergency investigation, an order to sell the family residence and the appointments of
minor’s counsel, a parenting coordinator and an Evidence Code §730 child custody
evaluation.”

It looks like an “acrimonious dissolution” on paper. But it’s really evidence of lawfare, family
court dysfunction, deprivation of Constitutional Rights, and Mr. Dragna’s failure to represent
his clients: our three children. And it suggests many things you could ask Mr. Dragna, like:

• Who filed the first DVRO and why? (A: Dad, because UCI Police & CPS told him to do it.)

• Why was there an Emergency Investigation? (A: A nurse practitioner reported professor-
mom to CPS, who conducted an investigation which found that mom neglected her child by
withholding his ADHD medication.)

• Why didn’t Mr. Dragna support the Emergency Investigator’s “strong recommendation”
for a secondary investigation? (I can’t even conjure a defensible answer to this question.)

• Why did the Court order the sale of the subsidized home on UC Irvine’s campus—even
though UC Office of the President (UCOP) doesn’t require it and our children need a
place to live? (A: Homes are money sources for lawyers and “family court professionals.”)

• Why did the custody evaluator recommend that dad, not mom, have primary custody—in
the children’s home? (A: The custody evaluator concluded that dad was a good parent &
the primary caregiver—and recommended that mom get a full psychological evaluation.)

• Why 29 hearings? (A: Financially motivated delay tactics, strategic ex parte motions, and
continuances for the many times the Court was “dark,” unavailable, or without a judge.)

• Why didn’t Mr. Dragna object to a motion ordering the sale of our children’s only home—
with no notice of the motion—even though dad opposed the sale and had been waiting
for the Court to rule on his RFO for child & spousal support for 23 months! (now
43 months, and counting)? (A: The family court system is broken and too often serves
lawyers, “court professionals,” and abusers—instead of children and protective parents.)

C. Why you should reconsider my complaint about Mr. Dragna.

It’s hard to imagine a better candidate for a Local Rule 12(e) investigation since:

• I made what you called “serious allegations” about Mr. Dragna;

• Our case is well-documented;

• Mom influences the lives of thousands of children as an expert and “teacher of teachers”;

• Dad maintains that he (and two witnesses) confronted professor-mom—with offers of

help & unconditional love—about her gaming addiction and online sexual relationship
with a 17-year-old high school student; and

• Dad maintains that professor-mom rejected all offers of help & unconditional love,
choosing instead to retaliate with 100% false domestic violence allegations.

“Within the child lies the fate of the future.” Dr. Maria Montessori
 D. California Public Records Act request for information about Rule 12(e) complaints.

Local Rule 12(e) was enacted on July 1, 2011. In that span of more than ten years:

• How many Rule 12(e) complaints have been submitted to the Supervising Judge?

• How many of the submitted complaints were investigated?

• How many of the investigated complaints resulted in consequences for lawyers?

• What consequences?

If you or your staff cannot provide this information to me, please direct me to the person at
the Court responsible for processing requests made under the California Public Records Act.

E. Conclusion.

Mom, currently a UC Irvine Associate Professor of Education, threatened to “break me” by

forcing our family into “the system” which would “hurt our children.” And then she did it.
And she was right: it has hurt our children, badly. For over two years, Mr. Dragna could have
represented our children’s “best interests.” Instead, he represented himself while preventing
me from advocating for our children. The “entire electronic legal file” you reviewed supports
my complaint and compels an investigation of Mr. Dragna’s role in our case. Now that you’ve
reviewed the file, you know it’s a case with significant ramifications.

I didn’t think our case would take more than a few months because mom’s lies were obvious,
the witnesses were many, and the evidence was overwhelming. I was relieved when CPS and
UCI Police sent me to your Court to “get an order so we can protect you and your children.”
On January 3, 2018, I was so naive about the family court system. Not anymore: now I know.

My heart breaks for the Orange County children and protective parents who, for decades,
have been pillaged, traumatized, and then discarded by the family court system. I know how
those protective parents feel. To the extent possible, I want our case to help reform the family
court system—and help the children and protective parents trapped in it.

I hope you choose to use my complaint as a “useful tool[] for the Court to reaffirm and
strengthen public trust in our court system.” But whatever you choose, I will continue to
protect our children while confronting Institutional Betrayal—with Courage—at UC Irvine
and Lamoreaux Justice Center.

Please consider using my Rule 12(e) complaint to shine some California sunlight on our case,
fitting since UC Irvine’s motto is Fiat Lux. If you shine the light, the Truth will defend itself.

Respectfully,

Brad
Brad Conley
Conly
cc: Steve Dragna, Esq., court-appointed counsel for our three minor children
Brett Thorsteinson, Esq., counsel for AnneMarie McEvoy Conley, Ph.D.,
UC Irvine Associate Professor of Education

“Within the child lies the fate of the future.” Dr. Maria Montessori
 Tierney Anderson, UC Irvine Title IX Director
Richard Arum, Ph.D., UC Irvine School of Education Dean and Professor
Gwen Black, Director of Equal Opportunity/Affirmative Action
Nathan Brostrom, UC Executive Vice President, Chief Financial Officer, and
Systemwide LDO for Whistleblowers
Nancy Burley, Ph.D., UC Irvine Professor of Ecology & Evolutionary Biology
Ron Cortez, UC Irvine Vice Chancellor and Chief Financial Officer
Andrea Gunn Eaton, Esq., UC Irvine Chief Campus Counsel
Jacque Eccles, Ph.D., UC Irvine Distinguished Professor of Education
Hon. John Flynn, III, Orange County Family Law Panel, Dept. L74
Jennifer Freyd, Ph.D., Founder & President of the Center for Institutional Courage and
University of Oregon Professor (Emerit) of Psychology
Elizabeth Griffin, UC Irvine Chief of Police (UCI PD)
Doug Haynes, UC Irvine Vice Chancellor for Equity, Diversity & Inclusion, Director of
ADVANCE, and Professor of History
Elaine Howle, CPA, California State Auditor
Ann Maguire, CEO, Wings for Justice (Newport Beach)
Joan Meier, Esq., Professor of Clinical Law and Director of the National Family Violence
Law Center at the George Washington University Law School
Dave Min, Esq., California State Senator (Irvine) and UC Irvine Professor of Law
Diane O’Dowd, Ph.D., UC Irvine Vice Provost of Academic Personnel (AP) and
Professor of Developmental & Cell Biology
Cottie Petrie-Norris, California State Assembly Representative (Laguna Beach)
Katie Porter, Esq., U.S, Representative (Irvine) and UC Irvine Professor of Law
Kirsten Quanbeck, Esq., UC Irvine Vice Chancellor of Equality & Diversity (OEOD),
Chief Ethics and Risk Officer (CECO), and LDO for Whistleblowers
Jane Stoever, Esq., UC Irvine Clinical Professor of Law and Director of UC Irvine’s
Domestic Violence Clinic & Initiative to End Family Violence
Hobart Taylor, Chairman, University Hills (UCI) Homeowners Representative Board
Suzanne Taylor, Esq., UC Systemwide Title IX Director

This letter challenges Supervising Judge Palafox’s 11/3 decision (letter, attached) to not
investigate my (amended) Local Rule 12(e) Complaint Regarding Minor’s Counsel.

Both of our letters reference the fact-filled, 47-page Declaration & Local Rule 12(e)
Complaint I filed into our case on 10/24.

You can download a court copy of the 10/24 Declaration & Complaint:

https://california.tylerhost.net/DownloadResource.ashx?
RID=1661b50d-1236-4184-9a9b-4f4b892235cd

“And whosoever shall offend one of these little ones that believe in me, it is better for him that a
millstone were hanged about his neck, and he were cast into the sea.” (Bible, KJV, Mark 9:42)

“Within the child lies the fate of the future.” Dr. Maria Montessori
 @,uµtrinr <trourt of <tralifornia
<trountu of ®rangt
341 THE CITY DRJVE
Chambers of
JU LIE A. PALAFOX ORANGE, CA 92868
FAMJL Y LAW SU PERVJS ING JUDG E PHONE: 657-622-5573
FAX: 657-657-8397

November 3, 2021

Brad Conley
38 Springacre
Irvine, CA 92614

Re: Annemarie Conley v. James Conley

Orange County Superior Court Case # 18D000296

Dear Mr. Conley:

We received your most recent complaint package regarding the above referenced case
dated October 13, 2021 . Your USPS Priority Mail envelope was provided to me on October
19, 2021.

This is your second written complaint against attorney Steve Dragna. The first complaint
was dated July 12, 2021 and directed to Judge Hurwitz who was the Supervising Judge of
Family Law at the time. When Judge Hurwitz transitioned to the civil panel shortly
thereafter, your complaint was re-directed to me as his successor.

As you know I responded to you on August 31 , 2021 based on the limited information I
had available because you failed to provide me with a case number and case name in your
first complaint against Mr. Dragna.

Now that you' ve provided this essential information in your second complaint, I was able
to review the entire electronic legal file. From this review I determined you are the
respondent in a still pending dissolution proceeding filed by the petitioner, Annemarie
Conley on January 11 , 2018. The petition and your response confirm a fourteen-year
marriage, a disputed date of separation in either October of 2017 or January 2018 and three
minor children. 1 Your last appearance before Judge Flynn was on September 14, 2021 . The
matter is now set for a three-day trial beginning February 7, 2022.

1
Your ch ildren are currently ages 11 , 13 and 16.
l,upcriDr <!tourt of <lialiforniu November 3, 2021
<liaunt11 of @rungt

Page 2

Since the action was filed it is clear this is a highly contentious and acrimonious dissolution
as evidenced by almost four years of litigation, four requests for temporary orders, mutual
requests for domestic violence restraining orders, four motions, twenty-nine hearings, an
emergency investigation, an order to sell the family residence and the appointments of
minor's counsel, a parenting coordinator and an Evidence Code §730 child custody
evaluation.

Although I now have a better understanding of the circumstances and dynamics of your
case and appreciate your ongoing frustration with the process, and in particular Mr.
Dragna's role in the custody issues, as previously explained, dissatisfaction is not
something that can be corrected witluepetitive .complaint letters to the supervising judge.

Although you were previously advised Mr. Dragna is not a court employee and he was
appointed Minor's Counsel pursuant to Family Code §3150 by Judge Flynn at a hearing
on June 19, 2019, I confirmed Mr. Dragna met the qualifications for appointment as
Minor's Counsel set forth in California Rule of Court 5.242 and required by Local Rule
712(e). Nonetheless you are again requesting, in my role as Supervising Judge for the
Family Law panel, I review Mr. Dragna's performance under Local Rule 712(e).

First, Local Rule 712(e) does not require the Supervising Judge review Minor's Counsel
performance in a particular case. Nor does it mandate I consider the merits of your
grievances. As you were told before, those are best directed to the assigned judge in your
case.

Second, it appears that has already been done. The electronic legal file confirms your
complaints against Mr. Dragna were set forth in two detailed declarations you filed with in
your dissolution case on July 20, 2021 and August 5, 2021. These were considered by
Judge Flynn at the last hearing on September 14, 2021. The minute order confirms Judge
Flynn found no impropriety and stated he would take no action Oll these ~omplaints.

For the reasons expressed herein, like Judge Flynn who certainly has more knowledge of
the underlying facts and circumstances of your case and Minor's Counsel's role, I find no
evidence of impropriety based on the materials you presented to take any action.

Sincerely,

Supervising Judge, Family Law Division

Orange County Superior Court