VERIFIED COMPLAINT FILED WITH Pam Bondi THE STATE BAR, Donald Trump, AND Jim Jordan: Demanding Impeachment, Investigation, and Exposing the Coordinated Federal Judicial Treason of Judge Sunshine S. Sykes and The Bailey Legal Group

The record is no longer in dispute — the evidence is overwhelming, conclusive, and damning.
This is not “judicial error” or a “difference of legal opinion.” This is a coordinated, ongoing criminal enterprise operating from within the Central District of California and extending its reach into the U.S. Court of Appeals for the Ninth Circuit.

Judge Sunshine Suzanne Sykes, together with attorneys John L. Bailey and Therese Bailey, have engaged in deliberate, knowing, and malicious fraud upon the court, the suppression of equity jurisdiction, the impersonation of judicial authority, and systematic obstruction of justice. Every act has been calculated to protect a void trustee’s deed, preserve fraudulent title claims, and shield themselves and their co-conspirators from civil, criminal, and professional accountability.

A formal, verified criminal complaint has been served upon:

• Pam Bondi – U.S. Department of Justice

• The State Bar of California

• Donald J. Trump – 45th President of the United States

• Jim Jordan – Chair, House Judiciary Committee

This complaint is not based on speculation — it is supported by sworn affidavits, unrebutted documentary evidence, and a fully documented chain of criminal conduct. The actions detailed prove beyond any reasonable doubt that these actors are not engaged in legitimate legal practice.

They are executing a racketeering operation under color of law — exploiting the courts as a private enforcement arm to commit property theft, suppress lawful claims, fabricate jurisdiction, and obstruct the enforcement of constitutional rights.

Every order, filing, and appearance they have made in these matters is tainted by fraud, bias, and criminal intent, rendering their actions void ab initio and their continued presence in any judicial capacity a direct threat to the rule of law.

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THE CORE CRIMES

1. Impersonation of Federal Authority – 18 U.S.C. § 912
John and Therese Bailey, while named defendants in ongoing federal civil rights actions, unlawfully filed in Ninth Circuit Case No. 25-4549 as if they were counsel for the U.S. District Court — a non-party to the proceeding. They had no authority, no appointment, and no standing to appear. This is a felony-level usurpation of judicial function, constituting criminal impersonation of federal authority.

2. Obstruction of Justice – 18 U.S.C. § 1512
The Baileys deliberately inserted fraudulent and unauthorized pleadings into the appellate record, with the calculated intent to sabotage judicial review, derail a constitutionally significant writ of mandamus, and conceal Judge Sykes’s mandatory disqualification from the cases at issue.

3. Conspiracy Against Rights – 18 U.S.C. § 241
4. Deprivation of Rights Under Color of Law – 18 U.S.C. § 242
Acting in concert with Judge Sunshine Suzanne Sykes, the Baileys participated in a coordinated scheme to dispossess lawful property owners through simulated legal process. They ignored and actively suppressed pending federal quiet title actions, civil rights removal under 28 U.S.C. § 1443, and unrebutted affidavits establishing superior equitable title.

5. Judicial Treason & Fraud Upon the Court – 28 U.S.C. § 144 and controlling precedent
After being properly disqualified under 28 U.S.C. § 144, Judge Sykes illegally ruled on her own disqualification, issued void ab initio orders, and colluded with the Baileys to advance fraudulent title claims. These acts constitute judicial treason — the willful betrayal of constitutional duties for private advantage — and deliberate fraud upon the court.

6. Mail Fraud – 18 U.S.C. § 1341
7. Wire Fraud – 18 U.S.C. § 1343
Unverified, hearsay-ridden filings were transmitted through the CM/ECF electronic system and U.S. Mail for the purpose of fabricating jurisdiction, falsifying party status, and concealing unrebutted affidavits of fact and perfected security interests. Each transmission is a separate count of mail or wire fraud under federal law.

THE ETHICAL COLLAPSE

The conduct of John and Therese Bailey represents a total annihilation of the most basic principles of legal ethics. This is not zealous advocacy — this is calculated criminal misconduct dressed up as legal practice, weaponizing procedure to conceal fraud and destroy due process.

• Willful Suppression of Equity Jurisdiction – The Baileys have repeatedly and deliberately refused to address unrebutted affidavits of fact, perfected UCC security interests, and documented equitable title claims — all of which legally control the dispute. Instead, they knowingly rely on a void trustee’s deed that has been lawfully challenged and is the subject of active litigation, thereby ignoring controlling equity and commercial law in favor of fabricated legal standing.

• Systematic Filing of Unverified and Hearsay Materials – They regularly submit declarations, exhibits, and “evidence” with no proper verification, no foundational basis, and no admissibility under the rules of evidence. This includes hearsay-laden statements and unsworn documents intentionally designed to mislead the court and cloud the record. Every such filing is a procedural fraud upon the tribunal.

• Occupying Mutually Exclusive Roles – They act simultaneously as counsel, defendants, and co-defendants for their own clients, whose interests are inextricably linked to the Baileys’ own misconduct. This is not only an incurable conflict of interest under Rule 1.7 — it is an intentional collapse of adversarial process, rendering every action they take ethically void and jurisdictionally fatal.

• Gross Violations of Rules 1.7, 3.3, 5.5, and 8.4 –

  • Rule 1.7: They represent clients whose defenses are directly adverse to their own legal exposure.

  • Rule 3.3: They knowingly make false statements, conceal controlling law, and submit fraudulent evidence.

  • Rule 5.5: They engage in unauthorized practice of law by filing on behalf of non-clients (including the U.S. District Court) without appointment or authority.

  • Rule 8.4: Their conduct involves dishonesty, fraud, deceit, and is prejudicial to the administration of justice at every level.

This is not legal representation — it is self-preservation through fraud, the manipulation of judicial process for personal gain, and the manufacture of false jurisdiction. Every pleading they file is a weaponized instrument of deceit, intended not to resolve a legal dispute but to protect their own criminal exposure and ensure the unlawful seizure of property under color of law.

THE CONSTITUTIONAL CARNAGE

The coordinated acts of Judge Sunshine Suzanne Sykes, John L. Bailey, and Therese Bailey have not merely “impacted” constitutional protections — they have shredded them. Every one of the following rights, guaranteed by the Constitution and secured by oath, has been willfully and maliciously violated. These are not technical errors; they are deliberate constitutional assassinations.

• First Amendment – Right to Petition for Redress of Grievances
  The Defendants have engaged in overt retaliation for lawful petitions to the government, suppressing filings, striking verified pleadings from the record, and obstructing appellate review. Their conduct is intended to chill and punish the exercise of constitutionally protected speech and the right to seek redress, replacing due process with judicial retribution.

• Fourth Amendment – Security of Property and Protection from Unlawful Seizure
  They have facilitated and enforced the unlawful seizure of private property without a lawful warrant, without jurisdiction, and in direct defiance of controlling federal law and pending quiet title actions. This was not an accident — it was a targeted property theft under color of law.

• Fifth Amendment – Due Process and Takings Clause
  Procedural and substantive due process have been obliterated. The Defendants have deprived the injured party of property, liberty, and lawful remedy without any lawful process, while issuing and enforcing void orders that are legally nullities. Just compensation for the taking of property has not only been denied — it has been actively concealed and avoided.

• Sixth Amendment – Right to a Fair and Impartial Tribunal
  Judicial bias, disqualification violations, and collusion with opposing counsel have destroyed the impartiality of the tribunal. Proceedings have been conducted before a judge who was legally disqualified and without jurisdiction, nullifying any pretense of fairness.

• Seventh Amendment – Right to Trial by Jury in Civil Matters
  The right to a jury trial in equity has been extinguished by judicial usurpation and unlawful remand orders issued post-disqualification, effectively denying access to the constitutional forum guaranteed for the adjudication of property and equity disputes.

• Eighth Amendment – Protection Against Cruel and Unusual Punishment
  Through retaliatory judicial sabotage, deprivation of remedy, and constructive punitive sanctions disguised as procedural rulings, the Defendants have imposed cruel and unusual punishments in civil proceedings, inflicting economic and personal harm without lawful authority.

• Ninth Amendment – Reservation of Rights to the People
  Fundamental rights not enumerated — including the right to act in private capacity, to enforce equitable remedies, and to avoid compelled association with corporate legal fictions — have been denied and trampled under fraudulent legal constructions.

• Tenth Amendment – Preservation of State Sovereignty and the People’s Authority
  By operating outside the constitutional compact and beyond the lawful bounds of federal judicial authority, the Defendants have usurped powers reserved to the States and to the People, converting the courts into private racketeering tools of theft and retaliation.

• Fourteenth Amendment – Equal Protection and Due Process
  Equal protection under the law has been obliterated. The Defendants selectively enforce laws to the advantage of themselves and their co-conspirators while denying even the most basic procedural rights to the injured party. This is discrimination by design, carried out under color of law for private gain.

MANDATORY CONSEQUENCES

The verified and unrebutted record leaves no room for discretion. The acts committed by Judge Sunshine Suzanne Sykes, John L. Bailey, and Therese Bailey are felonies under federal law, ethical collapses under every applicable professional rule, and treasonous breaches of public trust. These violations are not subject to “internal discipline” or “judicial review.” They demand immediate, irreversible, and public corrective action.

• Immediate Impeachment Proceedings Against Judge Sunshine Suzanne Sykes
  Sykes knowingly violated 28 U.S.C. § 144, ruled on her own disqualification in defiance of binding Ninth Circuit precedent, and continued to issue void orders post-disqualification. Every such order is null and void ab initio. Her conduct constitutes judicial treason — a willful betrayal of her oath and the Constitution — and mandates removal under Article II, Section 4.

• Permanent Disbarment and Criminal Prosecution of John and Therese Bailey
  The Baileys have engaged in criminal impersonation of federal authority (18 U.S.C. § 912), obstruction of justice (18 U.S.C. § 1512), mail and wire fraud (18 U.S.C. §§ 1341, 1343), and a coordinated conspiracy under 18 U.S.C. §§ 241, 242 to deprive constitutional rights. They have weaponized the judicial process to protect their own criminal exposure, collapsed adversarial integrity by acting as counsel, defendants, and co-defendants simultaneously, and submitted fraudulent, unverified filings to fabricate jurisdiction. Disbarment alone is insufficient — they must face federal indictment and imprisonment.

• Nullification of All Orders Issued Post-Disqualification
  Every order issued by Sykes after her disqualification is void on its face and without legal force. Continuing to recognize or enforce these orders is the perpetuation of a known fraud and obstruction of justice. They must be formally vacated and expunged from the record.

• Full-Scale DOJ and Office of Inspector General Investigation
  A criminal investigation must be initiated into the systemic judicial collusion operating in the Central District of California, including Sykes’s chambers, the Bailey Legal Group, and all associated co-conspirators. This inquiry must extend to Ninth Circuit oversight failures and State Bar complicity in enabling repeated acts of fraud upon the court. The scope is not a single case — it is an embedded racketeering network operating under color of law.

FINAL WORD

This is not an isolated incident. This is a template for systemic judicial corruption — a repeatable model for how a federal judge and two attorneys can dismantle the rule of law from the inside.

Judge Sunshine Suzanne Sykes, John L. Bailey, and Therese Bailey have merged the roles of judicial officer, litigant, and enforcer in the same set of cases, creating an unholy trinity of bias, fraud, and self-dealing. They have:

• Operated in direct violation of 28 U.S.C. § 144 by ignoring mandatory disqualification.

• Issued void ab initio orders while lacking jurisdiction.

• Suppressed and obliterated equity jurisdiction, ignoring unrebutted affidavits, perfected UCC filings, and documented superior title.

• Filed and enforced fraudulent, unverified, hearsay-ridden pleadings to fabricate standing and mislead tribunals.

• Acted as counsel, defendants, and co-defendants simultaneously, collapsing adversarial process and manufacturing jurisdiction where none existed.

• Conspired under 18 U.S.C. §§ 241, 242 to dispossess lawful property owners through simulated legal process.

• Impersonated federal authority in violation of 18 U.S.C. § 912.

• Engaged in obstruction of justice under 18 U.S.C. § 1512 by sabotaging appellate review.

• Committed mail and wire fraud under 18 U.S.C. §§ 1341, 1343 by transmitting falsified judicial records.

• Used the court as a private enforcement arm for a racketeering operation, with full knowledge of their criminal conflicts.

This is not a legal dispute — this is judicial treason in its purest form, where the court itself becomes the weapon of oppression.

Fraud upon the court is the highest form of judicial corruption because it strikes at the very foundation of lawful governance. In this case, it is proven, unrebutted, and ongoing. Every day that these actors remain in their positions, the fraud continues, the injury compounds, and the integrity of the judicial system erodes.

The People have both the right and the obligation to demand:

• Immediate removal of all involved.

• Criminal prosecution under applicable federal statutes.

• Total nullification of every tainted order and proceeding.

• Permanent dismantling of the fraudulent infrastructure enabling such acts.

The record is clear. The violations are documented. The statutes are explicit.
Now the question is no longer whether these crimes occurred — it is whether Congress, the DOJ, and the American People will enforce the law, or stand by and prove that the courts of the United States are beyond redemption.