In a stunning demonstration of procedural incompetence, legal fraud, and deliberate obstruction, a Cross-Complaint filed by Marinaj Properties LLC, directed by Naji Doumit, has triggered a commercial and federal catastrophe now escalating toward indictment-level exposure. The latest filings—including a Verified Response and Conditional Acceptance with Motion to Expeditiously Strike and Demand for Sanctions—lay bare an airtight commercial record exposing the Defendants to tens of millions in lawful commercial liability, federal civil rights claims, and criminal prosecution under RICO.
🧨 WHO IS NAJI DOUMIT?
Naji Doumit, a retired Lebanese doctor residing in California —has willfully engaged in a fraudulent attempt to seize property held by multiple private trusts, backed by perfected UCC filings and lawful conveyance through recorded Grant Deeds. Mr. Doumit, believed to be a principal or affiliated agent of FOCUS ESTATES INC, has shown no legal knowledge, no commercial standing, and no recorded interest that predates the lawful conveyance of title. Yet, rather than engage the matter honorably, Doumit initiated and supported the filing of a Cross-Complaint so riddled with defects, falsities, and libelous accusations that it now places him directly in the path of federal indictment.
💣 THE CROSS-COMPLAINT: A CASE STUDY IN MALICIOUS FRAUD
Filed by attorneys John Bailey and Therese Bailey, the Cross-Complaint:
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Offers no verified rebuttal to the Plaintiff’s UCC-1s, UCC-3s, Grant Deeds, or Affidavits of Default;
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Contains blanket denials, conclusory allegations, and characterizes sworn, notarized exhibits as “fabricated” and “fraudulent” without any counter-evidence;
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Makes a fraudulent attempt to void perfected trust title by naming ALL CAPS entities and unincorporated trusts—each of which is trademarked and commercially protected.
By labeling lawful, notarized filings as “fraudulent” and “fake” in writing—without providing a single point-by-point rebuttal—the Cross-Complaint constitutes libel, slander of title, simulated legal process, and commercial defamation.
The result? Doumit and his attorneys have now walked head-first into full commercial dishonor and are personally and jointly liable for:
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Over $100,000,000.00 in damages as of record (with lien enforcement pending),
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Trademark and copyright violations at $1,000,000 per unauthorized use,
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Federal crimes including:
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Racketeering (RICO, 18 U.S.C. § 1962),
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Mail and wire fraud (18 U.S.C. §§ 1341, 1343),
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Conspiracy to interfere with rights (18 U.S.C. § 241),
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Slander of title and fraudulent conveyance,
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Obstruction of justice and simulated legal process.
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🧑⚖️ INCOMPETENT COUNSEL: A BAR COMPLAINT IN WAITING
Attorneys John Bailey and Therese Bailey, whose filings display a reckless disregard for commercial law, equity, and verified procedure, now face imminent bar complaints, civil liability, and criminal conspiracy exposure. Their conduct violates multiple subsections of Rule 8.4 of the Rules of Professional Conduct, including:
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8.4(c) – Engaging in dishonesty, fraud, and misrepresentation;
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8.4(d) – Prejudicing the administration of justice;
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8.4(g) – Knowingly assisting unlawful activity.
Their filings contain no admissible rebuttal, no verification, and serve only to obstruct, defame, and deprive the Plaintiffs of lawful relief—making them complicit in every criminal and commercial violation advanced by their client.
These attorneys are now the subject of demands for:
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Immediate disbarment proceedings,
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Civil RICO liability as co-conspirators,
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Claims under FARA (22 U.S.C. § 611) for acting as unregistered foreign legal agents in administration of private American trust property.
📜 VERIFIED RESPONSE FILED: THE CHECKMATE THEY WALKED INTO
On record and now served upon all parties, the Verified Response and Conditional Acceptance of Cross-Complaint, with Motion to Expeditiously Strike and Demand for Sanctions, systematically dismantles every aspect of the Cross-Complaint. This document is not merely a rebuttal — it is a final, unrebutted commercial instrument that operates as a binding contract, having been conditionally accepted and left dishonored.
Within this Verified Response:
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Every allegation in the Cross-Complaint is met with point-for-point rebuttal grounded in perfected commercial instruments;
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The court is presented with Exhibits evidencing Grant Deeds, UCC filings, Affidavits of Default, Dishonor, and Non-Response;
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Counsel and defendants are now bound by commercial estoppel, tacit procuration, and constructive fraud liability.
Perhaps most devastating: Defendants’ repeated unauthorized use of the trademarked and copyrighted legal names — including but not limited to KEVIN WALKER™, DONNABELLE MORTEL™, and related trust entity marks — constitutes trademark infringement and unauthorized commercial use, creating a liability of $1,000,000 per use, per instance, as declared in the record.
These violations were not cured, rebutted, or lawfully excused.
And now?
There is no lawful exit. Marinaj Properties LLC, Naji Doumit, and attorneys John and Therese Bailey are trapped by their own dishonor, and legally bound to the terms of the Verified Conditional Acceptance. This means:
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Their Cross-Complaint stands in default;
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Their claims are commercially void;
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Their conduct has triggered full-scale commercial lien enforcement and federal removal;
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And each of them is now a target in the forthcoming federal RICO and civil rights complaint.
Whether the court strikes the Cross-Complaint now, or it is removed to federal jurisdiction and destroyed there — the result is the same:
They’re out of time, out of options, and out of legal ground.
What began as an arrogant legal stunt has become a self-executing collapse of their position. Every further move they make compounds the damage. Their silence would admit guilt; their opposition would deepen dishonor.
They are — in legal, commercial, and equitable terms — irreversibly screwed.
BEFORE THE COURT: NOTICE TO JUDGE RAQUEL A. MARQUEZ
This matter is currently before Raquel A. Marquez, presiding under appointment by the Governor of California pursuant to Article VI of the State Constitution. As a Superior Court judge, she is charged with upholding the laws of equity, protecting trust interests, and ensuring due process is not circumvented by simulated legal action or commercial fraud.
The Honorable Court has been formally noticed of the verified and unrebutted record—including perfected UCC filings, conditional acceptances, affidavits of default, and commercial instruments establishing full equitable title. Any further tolerance of the Cross-Complaint, or denial of Plaintiffs’ lawful remedy, would constitute judicial accommodation of fraud, ultra vires action, and a willful deprivation of rights under color of law, enforceable under 42 U.S.C. § 1983.
Judge Marquez now presides over a record where all material facts are closed and dishonor is established. The only lawful and equitable outcome is immediate dismissal of the Cross-Complaint, quiet title confirmation, and recognition of the Plaintiffs’ perfected standing. Any ruling to the contrary risks placing the Court itself into commercial liability and federal exposure.
🏛️ LEGAL SYSTEM IMPLICATIONS: COURT ON NOTICE
The Court has now received Final Notice. The record includes:
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Unrebutted affidavits,
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Perfected UCC filings and trust titles,
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Sworn Notices of Default, Dishonor, and Commercial Affidavit of Non-Response.
Failure to strike the Cross-Complaint, or refusal to enter equitable quiet title relief, would constitute:
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Ultra vires action,
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Fraud by judicial accommodation,
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Deprivation of rights under color of law (42 U.S.C. § 1983).
Removal to federal court is already prepared under 28 U.S.C. §§ 1331, 1343, 1441, 1443, with concurrent actions for mandamus (28 U.S.C. § 1361), and civil rights violation (42 U.S.C. §§ 1983, 1985, 1986).
📌 CONCLUSION
The incompetence of legal counsel, the unlawful actions of Naji Doumit, and the blatant fraud advanced in the Cross-Complaint have transformed what may have started as a civil dispute into a multi-jurisdictional commercial enforcement and criminal liability event.
This is no longer a matter of interpretation — it is a matter of enforcement.
Quiet title will be granted by equity, or the federal court will be compelled to intervene. Either way, the Defendants and their legal team are facing the full commercial, civil, and criminal consequences of trespassing against secured private trust property — and the record is already closed.
