Fraud Upon the Court and Judicial Complicity: Judge Marquez Aids RICO Conspirators and Attempts to Punish “the People”

A federal civil action now pending in the United States District Court, Central District of California, exposes an egregious and unlawful conspiracy orchestrated by attorneys Barry Lee O’Connor (Bar #134549), John Bailey (Bar #103867), Therese Bailey (Bar #171043), along with Naji Doumit, Mary Doumit, Daniel Doumit, MARINAJ PROPERTIES LLC, and THE BAILEY LEGAL GROUP.

The Verified Complaint, filed June 2, 2025, details a pattern of racketeering activity and simulated legal process in violation of:

• 18 U.S.C. § 1962 – Civil RICO (racketeering through fraud and obstruction),

• 18 U.S.C. § 1341 – Mail fraud,

• 18 U.S.C. § 1343 – Wire fraud,

• 18 U.S.C. §§ 241, 242 – Criminal conspiracy and deprivation of rights under color of law,

• 42 U.S.C. §§ 1983, 1985, 1986 – Civil rights violations, conspiracy, and neglect to prevent violations,

• California Civil Code §§ 1709–1710 – Fraud and deceit,

• California Civil Code §§ 3333–3346 – Damages, slander of title, and wrongful occupation of property,

• California Code of Civil Procedure § 760.020 – Quiet Title remedy.

Perfected Title Ignored, Fraudulent Trustee’s Deed Used to Steal Private Property

At the center of this action is a private trust property located at 31990 Pasos Place, Temecula, California 92592 (APN: 957-570-005). Plaintiff lawfully secured equitable and legal title through:

• Grant Deed #2022-0490841, recorded December 5, 2022

• Grant Deed #2024-0291980, recorded September 27, 2024

• UCC-1 Financing Statements Nos. 2024385925-4 & 2024385935-1, filed February 13, 2024

• UCC-3 Amendments Nos. 2024402433-7 & 2024411182-7, filed April 30 and June 15, 2024.

These filings perfected Plaintiff’s first-in-time, first-in-right security interest under UCC § 9-308, § 9-509, and California Commercial Code § 9509.

Despite this, the named Defendants recorded a fraudulent Trustee’s Deed Upon Sale (Doc. No. 2025-0017386) on January 17, 2025, which is void ab initio for failure to comply with due process, jurisdictional requirements, and notice obligations. This was done in commercial dishonor and in violation of both California Civil Code § 2924 and the Due Process Clauses of the 5th and 14th Amendments to the United States Constitution.

Attorneys Barry O’Connor and John Bailey: Architects of Simulated Legal Process

As officers of the court, Barry Lee O’Connor and John Bailey had a duty to uphold the law. Instead, the Verified Complaint charges them with:

• Knowingly recording and enforcing a void deed,

• Filing simulated court documents under false pretenses,

• Suppressing exculpatory commercial records,

• Threatening Plaintiff and defaming his title interest,

• Violating California Rules of Professional Conduct Rule 8.4(c), (d), and (g).

These acts constitute fraud upon the court, conspiracy to interfere with civil rights under 42 U.S.C. § 1985, and patterned racketeering conduct under 18 U.S.C. § 1961(1).

The exact causes of action are:

1. QUIET TITLE
2. Fraudulent Conveyance and Recordation
3. Slander of Title 
4. Racketeer Influenced and Corrupt Organizations Act (RICO) Violations
5. Civil Rights Violations — Deprivation of Rights Under Color of Law
6. Conspiracy to Violate Civil Rights
7. Obstruction of Justice
8. Mail and Wire Fraud
9. Forgery and Falsification of Public Records
10. False Claims and Use of False Pretenses in Judicial Process
11. Civil Conspiracy and Aiding and Abetting Liability
12. Federal Trademark Infringement, Dilution, and Commercial Identity Misappropriation
13. Commercial Fraud and Constructive Fraud
14. Unfair and Deceptive Business  Practices
15. Deprivation of Property Without Due Process of Law
16. Declaratory and Injunctive Relief

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MARINAJ PROPERTIES LLC and the Doumit Family: Racketeering Beneficiaries

Naji Doumit, a Lebanese national and principal of MARINAJ PROPERTIES, is accused of:

• Willfully acquiring private trust property through simulated legal process,

• Participating in fraudulent conveyance,

• Violating 18 U.S.C. § 1962(d) – conspiracy to engage in racketeering.

Mary Doumit and Daniel Doumit are also named as co-conspirators, having knowingly retained, transferred, and laundered title based on the fraudulent deed—direct violations of Cal. Civ. Code § 1709, and actionable as slander of title and unjust enrichment.

Unrebutted Affidavits, Conditional Acceptances, and Final Commercial Settlement Offers

The Verified Complaint details that Defendants:

• Failed to rebut multiple notarized affidavits,

• Remained silent in the face of conditional acceptances,

• Rejected a Final Commercial Settlement Offer dated May 15, 2025.

Under UCC § 3-505 and Cal. Commercial Code § 3505, these defaults constitute dishonor, tacit acquiescence, and trigger commercial estoppel. As the Ninth Circuit stated in Union Bank v. Winnebago Indus., 528 F.2d 95 (9th Cir. 1975):

“A notarial protest which conforms to statutory requirements creates a presumption of dishonor and default.”

Silence is acquiescence. As reiterated in Norton v. Shelby County, 118 U.S. 425, 442 (1886):

“That which is unrebutted becomes the truth in law.”

Judicial Complicity: Judge Rachel A. Marquez

The complaint also implicates Judge Rachel A. Marquez of Riverside County Superior Court for refusing to enforce jurisdictional boundaries and instead enabling the fraudulent actors. Rather than sua sponte striking the void Trustee’s Deed or dismissing the baseless Cross-Complaint, Judge Marquez issued OSC orders targeting sui juris litigants like Plaintiff, while ignoring violations by officers of the court.

This constitutes judicial fraud, abuse of discretion, and violation of public duty under California Government Code § 1222 and Cal. Civ. Code § 3523 (“For every right, there is a remedy”).

Prayer for Relief: Quiet Title, Injunctive Relief, RICO Treble Damages

The Verified Complaint demands:

• Quiet Title under Cal. Code Civ. Proc. § 760.020 and 28 U.S.C. § 2201,

• Injunctive relief against any further action by Defendants,

• Treble damages under 18 U.S.C. § 1964(c) for RICO violations,

• Slander of title and commercial damages under Cal. Civ. Code §§ 3334, 3346,

• Striking of the void deed under California case law (Dimock v. Emerald Properties, 81 Cal. App. 4th 868 (2000)),

• Declaration of estoppel and commercial default,

• Referral for criminal investigation under 18 U.S.C. §§ 241, 242.

This lawsuit is not speculative—it is a fact-based, unrebutted, verified claim supported by public filings, UCC instruments, and a perfected commercial record. The question now is whether the federal court will uphold the rule of law—or allow a state-sanctioned property theft ring to go unpunished.

Fraud vitiates everything it touches. And now the record speaks for itself.