ATTACHMENT 11- REASONS I DISAGREE
Case Number: _________________
This attachment supports my response to Section 11 of Form CH-120 (Response to Request for
Civil Harassment Restraining Orders). Accordingly, I state as follows:
1. Kaiser Foundation Hospitals declined to provide me accommodation via a letter that I received back
in January 2021, acknowledging that I have a psychological trauma, triggered by incident that
occurred back in August 28, 2020, which was a conflict with a manager at Kaiser, which has spiraled
out of control and escalated to this level. Instead of acknowledging fault, SCPMG has used brutal
and ruthless authority to punish me for putting that manager on notice that her actions did not follow
HIPPA protocols and facility protocol surrounding her actions on August 28th 2020.
2. Since then, it has been a ruthless campaign to destroy me emotionally, psychologically, and
professionally which led to false reports sent to the BRN, RN license revocation and a report sent to
the National Bank for health care workers.
3. Lisa Magorien has all the facts surrounding the conflict on August 28, 2020, and all the mental
health records that clearly show the liability of SCPMG. All the emails she is filing are evidence of
the psychological trauma that has been ongoing since August 28, 2020.
4. I have made attempts to seek legal redress in the Courts, which cases are ongoing. In said case(s), all
my previous attorneys colluded with Kaiser. Notably, I signed a retainer with Hershey Brenan for
SCPMG, but judge Kleifield relieved him as counsel under the Defendant’s cooperate name of
Kaiser Foundation Hospital.
5. My former attorney Gary Carlin, clearly communicated with me with email subject title SCPMG,
but put Kaiser Foundation Hospital as cooperate Defendant. Said attorney put Kaiser’s name, while
disregarding my attached W2s and wage statements, which reflected the correct name for the
Defendant. Attorney Carlin never bothered to correct his significant error of naming the incorrect
entity and Attorney Hershey failed to make any amendment himself.
6. Given that both attorneys colluded with Kaiser, my tainted reputation based on the aggressive
spreading of vicious rumors about me, I am unable to get any help with legal representation.
7. I am constantly exposed to the triggers and I am being mobbed by Kaiser, the BRN and the attorney
general office all by myself and experiencing a crisis due to the overwhelming psychological
pressure from this coordinated mobbing in a pathological effort to get me to back off from my
lawsuit.
8. I am a single mother, fighting alone, as my license has been revoked as a result of this lawsuit, for no
just cause, and this is obviously a ruthless abuse of power and authority by the attorney general
office to get involved and harass me at my home by sending two investigators to my home to
intimidate.
9. I am being viciously bullied by the above mentioned entities and only lashing out in response to
what they are doing to me.
10. I have no history of this sort of behavior anywhere else. This is an extreme and extraordinary
circumstance as relates to this situation.
11. I have never harassed any one at their home.
12. Lisa filed this restraining order because she was served at her home as a third part to the case, to
testify separately from Kaiser.
13. She became very distressed about being served at her home, and told the processor Server that she
will file a restraining order.
14. I live in Los Angeles and I am not a threat to Lisa Magorien.
15. Lisa who has exhibited nothing but frivolity. She violated her duties as Attorney (Bus. & Prof. Code,
§ 6103) by misleading the Court (Bus. & Prof. Code, § 6068, subd. (d)) and by committing acts of
moral turpitude, dishonesty & corruption (Bus. & Prof. Code, § 6106).
16. First, Lisa has blatantly abused the court’s process. Notably, she has made incessant attempts to bar
me from seeking justice. It is Lisa’s covert intention to present me as a vexatious litigant, to
ultimately curtail my right to approach this Honorable Court in pursuit of legal redress. On or about
February 6, 2023, in Esther Atam v. SCPMG, Case No. 22STCV37929 at the Superior Court of
California, County of Los Angeles, Lisa filed an ex parte application to dismiss my complaint, as
counsel for SCPMG. She field said ex parte application while ignoring my Request for Admission of
Facts (hereinafter “RFA”).
17. On or about January 3, 2023, I sent the Defendant a Request for Admission of Facts. At the time of
filing this response, Defendant has not yet filed any response to my RFA. Interestingly, Lisa
continues to make other filings in the court, while ignoring my RFA. For instance, on or about
January 13, 2022, (ten days after I filed her RFA), Lisa filed an Answer to my Complaint.
Consequently, she filed the ex parte application on February 6 th , all the while ignoring the RFA. It is
trite law that as officers of the court, attorneys are subject to duties of candor, decorum, and respect
for the tribunal before which they appear. Hollingsworth v. Perry, 133 S. Ct. 2652, 2672 (2013). An
attorney’s duty of candor is so fundamental that a violation of that duty may lead to suspension. In re
Gordon, 780 F.3d 156, 161 (2d Cir. 2015). The duty of candor is, if anything, more critical when ex
parte applications are made to a court. The Model Rules of Professional Conduct provide that "[i]n
an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the lawyer
that will enable the tribunal to make an informed decision, whether or not the facts are adverse." See
Model Rules of Prof’l Conduct R. 3.3(d) (2016). Lisa is therefore in violation of her duty of candor
to the tribunal, by filing the ex parte application and ignoring my RFA, when there was no
emergency to justify said application.
18. Further, Lisa attempts to have me classified as a vexatious litigant, while I have only been making
attempts to pursue justice. At no point have I made any frivolous filing, or abused the court process.
Lisa cunningly intends to use all legal stratagems to alter the court’s perception of me, and
ultimately issue a decision against me. It follow’s Lisa is bent to cloud SCPMG’s liability, because
she understands how SCPMG is liable and/or blameworthy as alleged in my complaint.
19. Lisa’s efforts are mere distractions, to shift the Court’s focus from the substance of the case. The
distractions, including the Restraining Order, are therefore frivolous. A filing is frivolous where it
can be said that it indisputably has no merit, such that any reasonable attorney would agree that it is
totally and completely without merit. Corbett v. Hayward Dodge, Inc. (2004) 119 Cal.App.4th 915,
922. As a licensed attorney, Lisa is aware that her filings have no merit, and that she has no
justification or good cause to have me issued the Restraining Order.
Dated: ____________
Respectfully submitted,
Signature
_________________________
ESTHER TENDO ATAM
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