Treason Charged by Health Ambassador in Federal Case as Whistleblowers Expose CIA-linked Drug Church, Damaging the Nation and World Religions


Journalists Move Foreclosure Fraud and Racketeering Case to Federal Court Where Judge J. Michael Seabright’s Knowledge and Experience in Bringing White Collar and Organized Criminals to Justice Will Be Tested Against a CIA-linked Publicly-Censured Lawyer, Paul J. Sulla, Jr., Who Has Concealed His Real Estate Empire Built Around Hallucinogenic Drug Trafficking From Hawaii


Leonard G. Horowiz and Sherri Kane

Pursuant the Case of






Civ. No. 14-00413 JMS RLP

Removed September 12, 2014


The Truth in Health Science for Protecting Populations at Risk


Release: No. 2-Sulla, Jr./2014

Date Mailed: Sept 15, 2014

For Immediate Release


Treason Charged by Health Ambassador in Federal Case as Whistleblowers Expose CIA-linked Drug Church that is Damaging Citizens Across America and the Religious World

Honolulu, HI— In U.S. District Court, a foreign ambassador certified by the U.S. Department of Foreign Affairs, Trade and Development has charged a Hawaii lawyer with treason against the United States, pursuant to an organized criminal conspiracy to deprive the diplomat of his rights and properties. The charges involve a secret CIA-linked drug trafficking “church” fueling a real estate empire built around the use of a hallucinogenic drug to “discover God” and replace traditional religions.

The astonishing charges were brought by Dr. Leonard G. Horowitz, an internationally known emerging diseases expert, pharmaceutical industry whistleblower, and Ambassador-at-Large for Canadian and Russian religious organizations developing rural health centers to administer humanitarian aid to poor people globally.

Horowitz filed on September 12, 2014, to remove the case from State to federal court after Hilo, HI, attorney, Paul J. Sulla, Jr. (“Sulla”), brought HESTER v. HOROWITZ over a title dispute that Horowitz claims is simple theft in a complex conspiracy to deprive his civil rights under “color of law.” The Harvard-trained doctor alleges Sulla conspired to steal the doctor’s geothermal estate on the Big Island, with co-conspirators including a KKK-linked neo-Nazi propagandist, Alma C. Ott, tied to retired FBI Bureau Chief, Ted Gunderson. Gunderson, after his death, became widely known for working under cover infiltrating “fringe” and “radical” groups, including  the “patriot,” “conspiracy,” and “alternative media” movements. It is now known that Gunderson, who Sulla named as a corroborating witness against Dr. Horowitz, worked with CIA psychological operations (PSYOPS) agent Barbara Hartwell, who published substantial evidence of her secret assignments with the Division Five Los Angeles Bureau Chief, Gunderson.

Ambassador Horowitz counterclaims against Sulla’s “Quiet Title Action,” that he was deprived of interstate and international trade, and defamed by pharmaceutical propagandists, “Ott & Company,” aiding-and-abetting Sulla in committing treason against the United States that has been officially at war against illegal drug manufacturers and traffickers since the Nixon Administration declared a “War on Drugs.” 

State Justice Elizabeth A. Strance, rebuked by the State of Hawaii Judicial Selection Committee for numerous complaints against her court, lifted a restraining order that Sulla obtained by defrauding the her to censor Horowitz, and his fellow journalist, Sherri Kane, from publishing—a website published by the humanitarian activists to petition law enforcers to investigate, indict, and convict Sulla on racketeering charges.

The doctor and Kane published their intelligence as members of the free press exercising their First Amendment rights to engage the media in “public participation in government.” They used to petition the Supreme Court of Hawaii to disbar Sulla, and, containing mainly court records, to enable community members harmed by Sulla’s actions, to better defend their families, properties, and Big Island youth from dangerous drug side effects.

Criminal counterclaims include hallucinogenic drug manufacturing and trafficking through a CIA-linked MKULTRA Program-likeAyahuasca Church.” Here, ill-informed “journeyers” consume the controlled narcotic “DMT” to “experience God.”

“These facts and illegal acts raise serious social concerns,” the doctor wrote, “risk medical emergencies, and underlie a cultural crisis in “One Nation Under God” that is Constitutionally founded on the principles of Christian monotheism (i.e., Judeo-Christian Levitical laws) that considers DMT use for ‘divine communion’ deadly sorcery and faithless hypocrisy.” 

The doctor referenced Acts 8:11; 13:8; Deuteronomy 18:9-10, and 18:14, that predicted nations falling because of “sorcery”—derived from the word “pharmakeia” or “pharmacy”—that is, prohibited (unlawful) use of mind-altering drugs.

Sulla’s acts raise serious and urgent legal questions of widespread public concern. The journalists asked federal court Judge J. Michael Seabright to consider these questions:  a) “Does SULLA’s ‘religious freedom’ cause ‘pharmaceutical slavery’—drug side effects, mental health problems, addiction disorders, social alienation, peer group conversions, and deadly physical risks?” b) “Does regular use/abuse of DMT alone, or with marijuana, risk public health and safety?”  c) “Does DMT, a psychosocially addictive and/or dependence-forming ‘ritualistic’ drug, commonly used with marijuana (‘THC’), like LSD, risk National Security as the hallucinogenic drug enterprise extends its culture (by propaganda, omissions and misrepresentations of risks, or downright consumer fraud) into traditional Judeo-Christian-Muslim communities?” and most importantly; and d) “Will trial jurors find for the Defendants’ clear and convincing evidence of federal agents’ and agencies’ complicity in Sulla’s racketeering activities and conspiracy to deprive the Defendants of their civil rights?”

“Answers to all the above questions are clearly affirmative,” Dr. Horowitz says, “because they have already been judged, prompting the Nixon Administration to officially declare the nation at ‘War on Drugs.’ That legislation is still in effect today.”

“Criminal statutes are, thus, being broken by Sulla, et. al.,” the doctor argues, writing to the Seabright Court: “Federal parties neglecting (with scienter) these matters that have aided-and-abetted DMT’s highly successful commercialization, preying on young people’s susceptibilities to drug use and abuse, promoting and leveraging widespread discontent with traditional religions; thereby marketing and developing a lucrative illegal drug substitute that promises to “fast track” “divine communion” for the “Future of Religion.”

The “Future of Religion” referenced by Dr. Horowitz is the published thesis of the CIA’s leading LSD and DMT scientist and academic propagandist, Dr. Stanley Krippner. Krippner mentored Sulla’s son, Sulla, III, who co-authored with Krippner the article, “Identifying Spiritual Content in Reports from Ayahuasca Sessions.” Their paper details group experiments consistent with the “religious ceremonies” conducted illegally in Hawaii at the Sullas’ “Ayahuasca Church.”

Krippner prepared his “Future of Religion” paper for the conference “LSD: Problem Child and Wonder Drug, An International Symposium on the Occasion of the 100th Birthday of Albert Hofmann.” This paper “was supported by the Chair for the Study of Consciousness, Saybrook Graduate School and Research Center, San Francisco, California, U.S.A.”

Seeking to recover more than $6 million in damages since 2004, Horowitz and Kane removed Sulla’s bogus “Quiet Title Complaint” from State to the federal court. The Complaint was Sulla’s latest of six (6) cases he filed against Horowitz, who hopes that by moving the case to federal court he can end the unfair advantage Sulla received from his fellow State court officers on the Big Island.

Sulla conspired with others in organized efforts to discredit the journalists/activists, to aid-and-abet property theft, unfairly compete in the natural healing industry, and ruin Horowitz’s markets in the American patriot and Christian communities.

Sulla named as his witness (in his dismissed defamation case against The HOROKANE) Alma C. Ott—a CIA-linked neo-Nazi anti-Zionist propagandist based in Utah. Ott, a conspiracy opportunist and blatant racist, conspired with the FBI’s Los Angeles Bureau chief, Ted Gunderson (most famous for handling the Marilyn Monroe and John F. Kennedy cases for the FBI’s “COINTELPRO” (i.e., Counter-intelligence Program).

Kane discovered these Sulla/Ott ties to the FBI and CIA during her investigation into America’s “Controlled Opposition.” A former Los Angeles Fox News investigator and copy writer, Kane identified a “cell” of Internet “trolls” directed by Gunderson and Ott, administered under the National Security MKULTRA umbrella, helping Sulla and others in Hawaii steal Ambassador Horowitz’s properties, including his health companies in California, Nevada, and Idaho.

The training of Internet propagandists for social engineering, demonstrated by Ott & Company, was provided by Britain’s Joint Threat Research Intelligence Group (JTRIG), corroborating Edward Snowden’s leaked intelligence. This abuse of the Internet to damage and destroy commercial competitors, including drug industry competition, was the subject of “NSA/CIA Trolls Destroy Heroes to Profit Villains: Snowden/Wikileaks Evidence Protection Racket for Death Industry”—a 36-minute newscast produced by The HOROKANE, now playing on Vimeo’s Revolution Television channel.

Sulla’s pattern of corruption and unreasonable immunity from prosecution and conviction is evidenced by his having been named, but never convicted, in several previous federal tax fraud cases (e.g., United States vs. Arthur Lee Ong, Cr. No. 09-00398 DAE, and United States vs. Bruce Robert Travis, U.S. Court of Appeals, Ninth Circuit. No. 10-15518; (March 10, 2010)(2007) in which tax officials convicted Sulla’s co-conspirators (i.e., his “clients”) for tax evasion, but not Sulla who agented their money laundering schemes. And all of this after Sulla’s Public Censure by the Supreme Court of Hawaii for arguing like a “reckless man” in the infamous federal case of Takaba v. Commissioner (119 T.C. 285, 295, 2002 WL 31818000).

Clearly, Sulla’s instant Complaint is consistent with his reputation, and conceals his conspiracy and pattern of malicious prosecutions committed in criminal contempt of multiple courts involving his shill “client” HESTER, further prosecuting, persecuting, and depriving citizen KANE, Ambassador HOROWITZ, and their corporations in California, Idaho, and Nevada, of their guaranteed freedoms and Constitutional rights, severely distressing and financially damaging the Defendants.


Sulla has used his shill “client” HESTER to violate federal laws; inter alia, Title 18. U.S.C., Section 242 for civil rights; and 18 U.S.C. § 1951, interference with commerce, robbery, extortion, and threats; Title 18 U.S.C. § 1346, scheming to defraud; 18 U.S.C. § 1957, engaging in monetary transactions in property derived from specified unlawful activity; Title 21 USC §856, maintaining drug-involved premises; and Title 18 USC § 2381, treason prohibition.

According to substantial Discovery compiled by the Defendants (trained as professional whistleblowers) Sulla is more than an attorney whose commercial investments parallel and compete directly with HOROWITZ’s and KANE’s.

Sulla is the chief “priest,” founder, and owner of the Big Island’s “Ayahuasca Church,” officially incorporated as THE ECLECTIC CENTER OF UNIVERSAL FLOWING LIGHT-PAULO ROBERTOSILVA E SOUZA, a Hawaii corporation that competes against traditional religions, including the religious theology of Horowitz’s RBD Judeo-Christian ministry. Sulla’s drug-based religion also competes against law enforcement and U.S. National Security interests in public health, particularly the mental health of America’s youth damaged by illegal drug use and abuse. Other Sulla incorporations compete directly against the Defendants’ health products and health services companies.

Sulla claims the mission of his  “ecclesiastical” “ECCLECTIC CENTER” corporation is to acquire and administer real estate to fund “community medicine;” whereas Horowitz is similarly situated as a doctor, religious group leader, and natural medicine expert granted stewardship of the subject (religious) property (previously called “Steam Vent Inn & Health Retreat”). The property features Hawaii’s only lava-heated steam saunas and geothermal rejuvenation pools. These valuable assets are viewed by Sulla as prize acquisitions for his companies that compete directly against Horowitz’s health products and educational services companies; including SULLA’s for-profit incorporations, THE HEALTH CONNECTION, INC., and HEALTH FOR WEALTH, “a Hawaii nutritional program and products company.” SULLA’s primary interests and investments, therefore, obviously compete with the Defendants’ mainland consumer health businesses, and prospective use of the subject property in all of the above commerce.

Consequently, Sulla’s “specified unlawful activities” include violations of the Sherman Anti Trust act (and Hawaii’s consumer fraud statutes), criminalizing unfair competition and restraint of interstate trade, as SULLA has committed by interfering directly with the Defendants’ interstate commerce, land grants, properties, personal and professional relationships, and personal investments.

Satisfying the legal definition of “racketeering activities” conducted by a “racketeering enterprise.” Sulla’s RICO enterprise is corroborated by the lawyer’s dimethyltryptamine (“DMT”) manufacturing and drug trafficking operation financing his “ECLECTIC CENTER OF UNIVERSAL FLOWING LIGHT” (a.k.a., “Sky of Hawai’I” “Ayahuasca Church”) that has concealed profits from “church services,” property conveyances, and illegal sales involving more than fifty (50) Big Island properties over the past decade—a large RICO enterprise (diagrammed in Exhibit “H”) that Sulla and his son, Sulla, III, defended in their SLAPP lawsuit (in Civ. No. 12-1-0417) as their “religious right” and “therapeutic practice” in “community medicine.”

Sulla’s criminal actions have all the markings of a concealed government double agent assigned as a protection racketeer for drug cartel commerce, known to, even authorized by, the CIA, DEA and FBI. In this enterprise, Sulla administers his own “ECLECTIC CENTER” within Hawaii’s $10B annual “Green Harvest” business, aided-and-abetted by law enforcers’ willful blindness to his felonies and DMT supply agency operating with substantial immunity against prosecution.

These claims are backed by more than a thousand pages of Discovery compiled over the past five years by The HOROKANE in five separate State cases, mostly court and Bureau of Conveyances records, evidencing Sulla’s organized crimes, “vertical abusive trust beneficiary schemes,” forgery for real estate fraud, money laundering, and drug trafficking, best explaining his resilience against civil and criminal complaints (and inability to sustain his claim of Defamation against these honest, hardworking, and intelligent Defendants in said SLAPP suit dismissed August 28, 2014, by Judge Elizabeth A. Strance). 

In this vein, Sulla has acted publicly as Hawaii’s most outspoken marijuana rights champion. His purported “client,” HESTER, like Hester’s purported “uncle” (Cecil Loran Lee) another purported SULLA “client” (the subject property Seller), were both convicted of trafficking marijuana in Arizona; Lee was also busted for the same crime on the subject property!

In fact, in violation of Hawaii Rules of Professional Conduct Rules 3.3, 4.1, and 8.4, Sulla concealed from the courts Lee’s criminal record and judicial punishment for having manufactured numerous documents to defraud courts and earlier buyers of the subject property. Lee did the same to defraud and damage Horowitz —facts known to, but concealed by, attorney Sulla, who had to have exercised a contingency contract with his bankrupted “client” Lee prior to Lee’s death in June, 2009. The contingency called for successfully extorting Horowitz and/or stealing the subject property for “the mob” under color of law. Only then would Sulla get paid.

Additional concealments by Sulla in this instant Complaint include the Ibarra Court rulings in Civ. No. 05-1-0196, that DENIED Foreclosure in Lee v. HOROWITZ et. al. Sulla dishonored the court system by foreclosing anyway, non-judicially, in contempt of court, circumventing due process most criminally by certifying multiple fraudulent transfers of Promissory Notes manufacturing $375,000.00 in “false debt” to evade and defraud Lee’s judgment creditors, including Horowitz and the RBD.  That “money from nothing” scheme bought Hester his illegal “color of title” and contested ownership of Horowitz et. al.’s $1 million estate for which Hester only paid $10.00, according to Sulla’s issued Quitclaim Deed. (See flow diagram below.)

                                          -end -



NOTE TO JOURNALISTS: Interviews with Ms. Kane and/or Dr. Horowitz can be arranged by e-mailing:


Judge Michael Seabright’s “911” ORDER DISMISSING COUNTS AND STAYING CASE 9:11:15.pdf

Sulla Memorandum on Motion to Dismiss 7:31:15.pdf



ANSWER from Sulla in Motion to Dismiss 6-15-15.pdf (24MB)


Plaintiffs Request for Leave to Publish Service or Alternatively Court Order May 31 2015.pdf


Rule 62(b) Motion to Stay or Dismiss. Motion 62(b) Complete Filing Optimized 10-5-15.pdf

Related (Original Case Civ. No. 05-1-0196) Response to Fourth Amended Final Judgment (filed by the Court without Motion June 19, 2015) MOTION FOR RECONSIDERATION OR ALTERNATIVELY NEW TRIAL w-Exhibits and Stamped 6-30-15.pdf (66MB)

Notice of Special Discovery Beth Chrisman Affidavit w- Exhibits 6-15-15.pdf

Opposition to Ex Parte Writ of Ejectment Letter 6-14-15  w-Exhibits.pdf

Emergency Motion For Injunctive Relief to Stay Process, Judgments, and Orders, Pending Appellate Court’s Rulings Pursuant to HRCP Rules 54(b) and/or 62(c)(g); Or Alternatively Dismiss this Case For: (1) Res Judicata, and/or (2) Newly Discovered Evidence of Fraud and Crime. June 10 2015 w- exhibits.pdf (57MB)


Notice of Discovery Documents May 11 2015 w/ Exhibits 1-30.pdf

Evidence of Forgery by Paul J. Sulla, Jr. to Create the Sham Foreclosing “Mortgagee” Included in the Discovery


Evidence Tampering by the Court’s Administration Noticed and Entered into the Ibarra Court Record at Disqualification Hearing

OPPOSITION TO MOTION FOR SUMMARY JUDGMENT w- Exhibits 4-4-15 Stamped by Court.pdf (87MB)

MOTION FOR SUMMARY JUDGMENT March 9 2015 w- Exhibits.pdf  (83MB)


EMERGENCY MOTION & MEMORANDUM 4-13-15 w- Exhibits.pdf



U.S. DISTRICT COURT CASE OF HESTER v. HOROWITZ et. al., Civ. No. 14-00413 JMS/RLP (Removed State Court Case -- Civ. No. 14-1-0304 (filed August 11, 2014)

Complaint to Quiet Title w: Exhibits 8-11-14.pdf(68MB)



RICO Special Discovery Statement LR33.1.pdf 

REMOVAL to Federal Court with Exhibits Sept 12 2014.pdf (30MB)





MOTION FOR INJUNCTIVE RELIEF  w/ Exhibits Dec  4  2014.pdf (57MB)

MOTION FOR ENTRY OF DEFAULT w/ Exhibits  Dec 9 2014.pdf (12.5MB)

EXPARTE COMMUNICATION DEATH THREATS w/ Exhibits Dec 15 2014.pdf (8.4M)

The following audio recording corroborates the evidence exhibited in the above filing, but was STRUCK by the court along with the entire filing. The federal court chose to avert “due process” involving the U.S. National Security Agency for having trained Mr. Sulla’s co-conspirators’ Internet libel and commercial disparagement campaign: Download . . .

Bracker and Nuccitelli feud.mp3

and Complaint about Nuccitelli to New York State Licensing Board.pdf (19MB including Exhibits)



The following is a record of the alleged “racketeering activities” and alleged “defamation” involving the parties in this case: 1) Paul J. Sulla, Jr., a Hilo, HI, attorney, and his son, 2) Paul J. Sulla, III, who brought the Defamation Complaint against, 3) Leonard G. Horowitz, an internationally known author and drug industry whistleblower, and 4) Sherri Kane, an investigative journalist partnered with Dr. Horowitz in publishing research regarding human rights violations:

  1. 1.June, 2003, predicate felon Cecil Loran Lee baited Horowitz to purchase Lee’s “Bed & Breakfast” in Pahoa, HI, for Horowitz’s ministry, The Royal Bloodline of David, for $550,000.00, with closing on January 15, 2004. Seller's Disclosure.pdf.

  1. 2.On July 10, 2003, Horowitz paid Lee $85,000 in advance of closing for Lee to payoff a high interest loan secured by the property that Lee concealed sourced from his conviction for marijuana trafficking from the property.

  1. 3.Lee also concealed he was being sued by Philip Maise, a man Lee had previously defrauded while selling the same property.

  1. 4.On-or-about January 7, 2004, a group of men (Cecil Loran Lee, Herbert M. Ritke, Ronn Rike, and Jason Hester) conspired to extort, defraud, and steal from Horowitz, leveraging his $85,000.00 downpayment and total $200,000.00 non-refundable escrow deposit.

  1. 5.The men’s torts and crimes were aided-and-abetted by two attorneys—Dan O’Phelan, who was sanctioned and left Hawaii, and currently practices in Alaska; and Paul J. Sulla, Jr., a Supreme Court of Hawaii publicly censured attorney with a pattern of involvements with Federally indicted “clients” convicted of tax-evasion and money-laundering using sham “religious” trusts and corporations set up by Sulla, Jr. as pled by Federal prosecutors and ruled by courts in: a)  U.S. v. TAKABA, Sulla Petitioner.pdf; b) US Tax Court vs. Ong, et al..pdf; and c) USA v. Bruce Travis Disqualitication of Sulla.pdf

  1. 6. Lee and Hester were both convicted of marijuana trafficking, and Sulla, Jr. is the leading marijuana rights activist and criminal defense attorney on the Big Island of Hawaii, best known for his purported advocacy of imprisoned “Marijuana Minister” Roger Christie.

  1. 7.On January 5, 2004, after Horowitz gave Lee the $85K downpayment, Lee and his domestic partner--alleged by Lee to be his legal “counsel”--Herbert Ritke, extorted Horowitz for $150K more than agreed. Ritke claimed the “trailor” (disclosed by Lee to be part of the sale since it was connected by utilities to the Bed & Breakfast, rented, but parked on County of Hawaii land; thus, was not rightfully Lee’s to sell) required more money to close the deal.

  1. 8.On January 6, 2004, Lee mailed Horowitz a revised extortion for $25K to settle the dispute. (See: Lee’s “Fire Sale” Extortion Letter of Jan. 6, 2004.pdf)

  1. 9.The next day, on January 7, 2004, Lee registered a sham church called “Revitalize, a Gospel of Believers” established exclusively to defraud Horowitz in the unfolding fraudulent mortgage transfer and foreclosure scheme. (See State of Hawaii Record: REVITALIZE GOSPEL OF BELIEVERS Initial Registration Jan 7 2004.pdf)

  1. 10. Within a week, Jason Hester, registered a fake address in Pahoa, and later falsely claimed he was Lee’s “nephew,” as certified by Sulla, Jr. in legal filings. (HESTER's Initial Address Non-Existent.pdf)

  1. 11. Hester was later designated as Lee’s “heir” to oversee the sham “church” and theft of property title by Sulla, Jr.’s non-judicial foreclosure.

  1. 12. On January 7, 2004, Horowitz appealed Lee’s certified mail delivered extortion to Island Title Company (the escrow holder), and Brenda Iaone, the title company officer, referred Horowitz to attorney Glenn S. Hara to draft a “writing” to settle the disputed and threatened closing. This “writing” superseded the mortgage, (according to paragraph 19 of Lee’s Mortgage to Horowitz, 2004.pdf).  Attorney Hara titled his remedial writing “Agreement for Closing Escrow.”

  1. 13. Predicting Lee and Ritke would attempt to foreclosure after the sale of the property, the Agreement for Closing Escrow contained most substantive paragraph (#1) indemnifying Horowitz (and his ministry) against foreclosure from lacking insurance or construction permits. (See: AGREEMENT FOR CLOSING ESCROW Certified True Original Copy.pdf.)

  1. 14. On January 14, 2004 Lee and Horowitz signed this true certified original Agreement for Closing Escrow that stated $25K would be paid to Lee beyond the $550,000.00 purchase price UPON THE RELEASE OF THE MORTGAGE following balloon payment due January 15, 2009.

  1. 15. On January 15, 2004, Horowitz, in Lee’s presence, delivered this quintessential closing document to Ms. Iaone at the title company to commence closing.

  1. 16. Hours and days following closing Lee and Ritke committed a series of acts designed to damage Horowitz and threaten foreclosure as reported to police in: a)  Criminal Complaint Case No. H-77469, 02-9-2004; b) April 22, 2004; Jay T. Kimura, Prosecuting Attorney, Re: Police Report No: H-80147-001, Charge (s): Extortion 1; c) April 29, 2004, U.S. Postal Inspection Service Addendum to Case H-80147-001: Mail Fraud and Harassment by C. Loran Lee; d) Case No. C-05022735 / C. Loran Lee, May 24, 2006, Department of Criminal Investigation, Officer Tom Poi; e) Detective Ian Leloy, Hilo Police Department Internal Affairs Dept., Tuesday, Oct. 12, 2010 Re: Investigation into Neglect in Case No. H-H 77469; 01-18-2004; 0-5022735; f) Harassment Complaint, Oct. 22, 2011, Officer Robert Silva, Case: C-11027655; g) Harassment Complaint, May 7, 2012, Officer Steffen, Case C12012644; h) Theft 2, May 7, 2012, C12012645, Officer Steffen; i) Perjury, May 25/June 12, 2012, Case No.: M-12025700; j) June 18, 2012, Per Assist, Case: M-12029892, Officer G. Kagimoto; k) and Harassment Complaint, July 23, 2012, Case No.: C12019411.

  1. 17. On Nov. 10, 2004, Lee filed said Agreement for Closing Escrow in his defense against Horowitz who filed a Breach of Contract lawsuit on October 14, 2004, in Civ. No. 04-1-0339. (Paul Hamano Reply to Complaint Civ No 04-1-0339.pdf)

  1. 18. A few months later, Lee altered Hara’s writing using Ritke’s home PC computer, removing the paragraph #1 from the Agreement, in order to bring the current Foreclosure Complaint in Civ. No.  05-1-0196. (See document comparisons and analysis by Third Party Intervenor, Philip Maise, in Agreement for Closing Escrow Series.pdf)

  1. 19. At trial in 2008, Lee and O’Phelan argued that Horowitz, not Lee, altered the document with no evidence of this whatsoever; notwithstanding the concealed Hara file proving Lee was the forger. Then the defrauded jury misruled, but nonetheless, awarded Horowitz $200,000.00 (his full deposit returned) for Lee having defrauded Horowitz in the sale of the property.

  1. 20. On February 23, 2009, the Ibarra Court issued an Amended Final Judgment that maintained the $200K jury award, but added reference to Horowitz having altered the document, vicariously indicting Glen S. Hara, whose file was concealed for unknown reasons during the trial. (See Finding of Facts and three Ibarra Court Final Judgments here: Ibarra Court Findings and Judgments.pdf)

  1. 21. According to the Hawaii Hoo hiki Court Record, attorney O’Phelan never officially withdrew as Lee’s counsel, and Paul J. Sulla, Jr. never officially entered as substitute attorney for O’Phelan, but on May 21, 2009, Sulla, Jr. noticed the court of his filing of Appeal No. 29841—an action obviously taken to reverse the $200K jury award, and, thus, evade judgment creditors Horowitz and third party Intervenor, Maise, who had beat Lee for $225,000.00 in damages in his case against Lee, in the Nakamura Court’s Civ. No. 01-01-0444, wherein Lee was ruled to have altered numerous documents for legal filings.

  1. 22. Paul J. Sulla, Jr., then aided and abetted Lee in manufacturing and certifying a series of new securities instruments, mortgages, and promissory notes, to create $375K in false debt that they conveyed into a new sham church in apparent violation of HRS §651C Uniform Fraudulent Transfer Act; HRS §485A(501;502; 508; 509), Uniform Securities Act (2002) HRS §414D Hawaii Non-profit Corporations Act; HRS § 708A-3 Money Laundering Prohibition; and HRS §842-2;6. Organized Crime Prohibitions. (See: FALSE PROMISSORY NOTE AND MORTGAGE FILINGS .pdf

  1. 23. On Feb. 3, 2009, after Lee evaded Horowitz’s multiple attempts at completing the balloon payment due, and gaining thereby a mortgage release, Horowitz made the final balloon payment due Lee to Maise, as per the Nakamura Court’s garnishment orders. (See: Final Balloon Payment Checks and Wire Transfer Records.pdf.)

  1. 24. Sulla, Jr. knew Horowitz had made the final balloon payments to Maise, but filed the fraudulent mortgage and promissory notes creating false debt anyway, fraudulently transferring the defunct $375K debt to the sham church.

  1. 25. Sulla, Jr. claimed (in Civ. No. 12-1-0417) to know Lee’s family very well; and falsely claimed Jason Hester was Lee’s “nephew,” but was later compelled by Horowitz’s publications to alter his false filing with the State, more recently claiming Hester is Lee’s “grand nephew,” but he is not that either.

  1. 26. Sulla lied about Hester being Lee’s “nephew,” or “grand nephew”, as a “Comprehensive Report” by private investigators, Baker Surveillance and Investigation Services (hereafter “BSIS”) confirmed HESTER is unrelated to Lee, except for common drug trafficking convictions. (Click cover sheet to download full document.)

  1. 27. Sulla, Jr. substituted the church and Hester for Lee upon Lee’s death as: JASON HESTER, AS SUCCESSOR OVERSEER OF THE OFFICE OF OVERSEER, OVER/FOR THE POPULAR ASSEMBLY OF REVITALIZE, A GOSPEL OF BELIEVERS, speciously registered at Ritke’s private residence. (See: Substitution of Plaintiff False "Nephew" Hester by Sulla .pdf.)

  1. 28. Yet, Sulla, Jr. testified on January 4, 2013, in the Strance Court, referring to HESTER as “the owner of the property . . . [HESTER] does want me, very much, to represent him in an ejection action to get his house, before the taxes take it and before it falls in for all the violations it has. He’s concerned about his investment and his rights, as the owner of the property that you [HOROWITZ] live in.” (See: Court Transcript Sulla Testimony Jan 4 2013 Re- Hester Grand Nephew and Ayahuasca Church.pdf)

  1. 29. The Final Judgment favoring Horowitz, and the Court’s balloon payment directive, was reinforced on July 22, 2008, with the Ibarra Court stating: “The remedy of foreclosure is denied but equitable relief has been granted . . . 3. Pursuant to the jury’s verdict, judgment for monetary damages [not special damages for fraud] is entered in favor of Defendants HOROWITZ in the amount of TWO HUNDRED THOUSAND DOLLARS and NO/100 ($200,000.00) and against Plaintiff LEE. 4. As to the allegation of fraud, paragraph 13 of the Complaint for Foreclosure [pertaining to the forged Agreement for Closing Escrow] filed June 15, 2005, pursuant to the jury’s verdict, judgment is entered in favor of Defendants HOROWITZ against Plaintiff LEE as the jury found the fraudulently altered Agreement for Closing was not the legal cause of Plaintiff LEE’s losses. . . . This final judgment disposes of all of the claims, counterclaims and cross-claims raised by any and all parties in this action. There are no remaining claims or parties. All other claims are dismissed.”  (See: Ibarra Court Findings and Judgments.pdf)

  1. 30. The Court, however, had obfuscated the matter of forgery in this conclusion, pursuant the “fraudulently altered Agreement for Closing” not being the legal cause of LEE’s losses.”

  1. 31. In fact, that altered Agreement had been the legal cause of Horowitz’s losses.

  1. 32. The epitome of fraud upon the court proximal to Horowitz’s severe financial losses, and severe long term emotional distress, occurred seventeen (17) months later, as a result of Sulla, Jr.’s and Lee’s further filings, prompting the Court’s AMENDED FINAL JUDGMENT (Feb. 23, 2009), and subsequent SECOND AMENDED FINAL JUDGMENT (Dec. 11, 2009; hereafter “SAFJ”) wherein its paragraph 4, Ibarra stated: “As to the allegation of fraud, paragraph 13 of the Complaint for Foreclosure filed June 15, 2005, pursuant to the Order Granting Plaintiff’s Motion for Judgment as a Matter of Law or Alternatively New Trial on Issue of Defendant’s July 6th Counterclaim for Fraud and Misrepresentation, filed on October 15, 2008, judgment is entered in favor of Plaintiff LEE against Defendants HOROWITZ.”

  1. 33. Horowitz attorney John Carroll’s Counterclaim for “Fraud and Misrepresentation” was beyond negligent, outrageously incompetent, or criminally complicit. (See: Carroll's Filing of DEFEFENDANTS' COUNTERCLAIMS.pdf )

  1. 34. According to Carroll, the Ibarra Court’s SAFJ was an “abomination,” indicting Horowitz and vicariously Glenn Hara by conceding to Lee, who the Court knew: a) to be a convicted felon; b) perjured himself during trial (as acknowledged by the Court); c) was a Nakamura Court certified repeat forger; and d) altered the Glenn Hara-drafted Agreement for Closing Escrow, as Horowitz testified and Carroll certified, as proven by the chain of records in the Hara File.

  1. 35. Equally troubling, in the SAFJ, Sulla, Jr. and the Ibarra Court, substituted the sham Plaintiff: JASON HESTER, AS SUCCESSOR OVERSEER OF THE OFFICE OF OVERSEER, A CORPORATE SOLE AND ITS SUCCESSOR, OVER AND FOR THE POPULAR ASSEMBLY OF REVITALIZE, A GOSPEL OF BELIEVERS (hereafter, “GOB”), that the Ibarra Court knew, or should have known, was a scheme to evade Lee’s judgment creditors, Maise and Horowitz, evade taxes, and compound fraud upon the court in violation of HRS §651C Uniform Fraudulent Transfer Act, and many other laws. (See: Substitution of Plaintiff False "Nephew" Hester by Sulla .pdf)

  1. 36. Attorney Carroll, Maise, and Horowitz each informed Sulla about Lee’s jaded history, and forgery of the Hara-drafted Agreement, but in violation of his rules of professional conduct, Sulla, Jr. aided-and-abetted the criminal conspiracy to steal money from Horowitz, or alternatively steal the property. (See Maise Letter to Paul Sulla 01 21 2009.pdf.)

  1. 37. On April 20, 2010, Sulla, Jr. committed contempt of the Ibarra Court’s three final judgments that each denied foreclosure, neglecting and dishonoring the Appeals Court pending decision on the matter as well, by conducting a fraudulent non-judicial foreclosure as agent for the sham GOB “church.”

  1. 38. Since then, Sulla, Jr. has fraudulently claimed HESTER’s rightful ownership of the “foreclosed property” in three more court cases other than Civ. No. 05-1-0196 (that is, Eviction Complaint Civ. No. 3RC-11-1-662; Defamation Complaint Civ. No. 12-1-0417), and the U.S. District Court case (Civ. No. CV12-00449 SOM KSC).

  1. 39. Sulla, Jr. unlawfully foreclosed on the property by “power of sale” and “mock auction” with “shiller” (fake bidder) HESTER, who Sulla, Jr. instructed to use the contrived “unlawful debt” (false claim of debt) as his bid and payment, (i.e., securities fraud for attempted theft of real property).

  1. 40. Attorney Gary Dubin was hired by Horowitz and Kane, who paid Dubin $6,000.00 to stop the illegal non-judicial foreclosure (NJF), but Dubin neglected to file even one pleading; so members of Horowitz’s ministry videotaped Sulla’s mock auction, and posted it on the Internet to bring police and public attention to this fraudulent foreclosure; hoping that prosecutors would arrest Sulla and Hester, and end the nightmare.

  1. 41. But with Dubin having filed nothing, in June, 2011, Sulla, Jr., as a concealed mortgagee “Lender” to Hester, directed HESTER to fraudulently file an Eviction Complaint against Horowitz’s ministry so that Horowitz could not defend pro se, and would need to hire an attorney to defend the corporation. (Civ. No. 3RC-11-1-662) (See: Eviction Complaint Filing June 21, 2011.pdf)

  1. 42. Leading up to this Eviction Complaint, on May 11, 2010, Sulla, Jr. recorded a QUITCLAIM DEED on the subject property with the State of Hawaii Bureau of Conveyances, using Ritke’s address and slandering title. (See: QuitClaim Deeds Sulla:Hester May 11, 2010 and June 9, 2011.pdf)

  1. 43. On June 9th-14th, 2011, Sulla, Jr. schemed, and acted, with HESTER to fraudulently evict Horowitz and his ministry members and caretakers from the property, as evidenced by:

a. June 9, 2011, Sulla, Jr. prepared, and HESTER co-executed, an illegal QUITCLAIM DEED transferring the property from the sham “church” to HESTER as an individual;

b. The same day, June 9, 2011, Sulla, Jr. prepared, and HESTER co-executed, an illegal Mortgage giving Sulla first lien on HESTER’s color of title pursuant the subject property and deed (See: SULLA MORTGAGE TO HESTER.pdf); and

c. On June 10, 2011, HESTER mailed a fraudulent threatening eviction notice to Horowitz and caretakers at the estate to vacate the premises.(See: Mail Fraud Eviction Notice June 10 2011.pdf)

  1. 44.On June 14, 2011, Sulla, Jr. recorded this illegal transfer of the aforementioned QUITCLAIM DEED to HESTER in violation of HRS §414D (Hawaii Non-profit Corporations Act); HRS § 708A-3 (Money Laundering Prohibition); and HRS §842-2;6. (Organized Crime Prohibitions), addressed to P. O. Box 758, Pahoa, HI.

  1. 45.The same day, June 14, 2011, HESTER (purportedly) recorded the SULLA-prepared $50,000.00 Mortgage on the subject property giving Sulla, Jr. (the supposed “Lender”) the right to foreclose on HESTER, for the shill’s failure to pay taxes. (See paragraph #3: SULLA MORTGAGE TO HESTER.pdf)

  1. 46.Secretly, as a concealed real party of interest as mortgagee in the subject property, on June 21, 2011, Sulla, Jr. counseled HESTER in filing the frivolous and fraudulent Eviction Complaint No. 11-1-662 , compelling Horowitz to commission attorney Dubin at a cost of nearly $19,000.00 to defend against the Eviction Complaint.

  1. 47. But instead of helping timely and effectively, Dubin extended damages by filing (through associate attorney Benjamin Brower) an incomplete and untimely Motion to Dismiss.

  1. 48.Following extended financial damages and severe emotional distress generated by the threat of being evicted, after HESTER’s Eviction Complaint was scheduled for trial instead of prompt dismissal, on January 23, 2012, Dubin Law associate Peter Stone pled effectively for the Freitas Court to dismiss the Eviction Complaint for lacking subject matter jurisdiction.

  1. 49.Then Sulla, Jr. continued his racketeering activity (also called “specified unlawful activity”) conspiring with HESTER and Ritke to extort and defraud Horowitz by mail fraud on March 27, 2012, sending a “NOTICE OF DEFAULT AND DEMAND FOR PAYMENT IN FULL,” that concealed his own interest in the property as HESTER’s mortgagee; instead claiming his “office represents Jason Hester, Overseer of the [‘church’] . . .”  (See: Sulla Demand For Payment In Full, May 27, 2012.pdf)

  1. 50.In that mail fraud, Sulla, Jr. falsely alleged Horowitz owed “Hester” $323,610.00 “AS OF MARCH 17, 2012.” 

  1. 51.By this time Horowitz and Kane had received communications from least a half dozen other Sulla, Jr. victims—people claiming they had been defrauded or otherwise damaged by Paul Sulla, Jr.’s actions as an attorney in real estate matters, mostly fraudulent foreclosure actions.

  1. 52.Four of these people gave Horowitz and Kane their contact information and asked for help from the journalists in telling their stories to help them gain relief. Two others were fearful and did not want to be further damaged by Sulla. Horowitz told each of them to report their cases to the police and Hawaii County prosecutors. (These people included: Edna Franco, Roberta Sonoda, and Allene Kaplan.) (See: AFFIDAVIT OF LEONARD G HOROWITZ June 5 2013.pdf)

  1. 53. Two other people, local businessmen, gave Kane and Horowitz background information about Lee and Sulla, evidencing their complicity in organized crime pursuant the subject property and/or drug trafficking. (Their names are: Russell Jones and Philip Maise.) (See: AFFIDAVIT OF RUSSELL JONES.pdf)

  1. 54.Another two men, Michael A. Sakell and Loney J. Salas, who were caretakers on the property, provided Horowitz with sworn affidavits relaying details about Mr. Sulla’s alleged drug trafficking operation from an “Ayahuasca church” north of Hilo, Hawaii, named the “Sky of Hawaii” church.  (See: AFFIDAVIT OF MICHAEL SAKELL .pdf and AFFIDAVIT OF LONEY J. SALAS.pdf)

  1. 55.Both men, who were not friends, described the way Sulla’s “volunteers,” who paid to take part in the “religious ceremony,” manufactured “medicine” containing the controlled hallucinogenic narcotic DMT.

  1. 56.On July 20, 2012, Sulla, Jr., supposedly “damaged” by Horowitz’s and Kane’s publications of the videotape of his mock auction, and the allegedly defamatory Civ. No. 12-1-0417--pursuant this Notice.

  1. 57.Horowitz and Kane do not believe they have defamed Mr. Sulla, simply told the whole truth, as materially evidenced, as they are not only the victims of his complicity in organized crime, but well known journalists and whistleblowers.

  1. 58.Horowitz and Kane have been financially devastated by their many years of fighting organized crime in the local courts, with financial losses beyond $6 million over the past nine years for Horowitz and his now insolvent ministry.

  1. 59.Horowitz and Kane, having been forced financially to defend pro se, have not done well in court, as this Order for Preliminary Injunction granted Sulla, Jr. to censor the website shows, despite their: a) qualified privilege as victims of crime seeking protection from law enforcers; b) absolute privilege as journalists covering a story of social importance; c) their Constitutional rights in the First, Fifth and Fourteenth Amendments guaranteeing equal protection under the law, and required due process; reflecting on case law in Sullivan v. New York Times and many other landmark cases that established what Sulla, Jr. must do, and cannot do, to win a defamation action in this case.

  1. 60.The Strance Court, however, has ruled by issuing the Preliminary Injunction, that Sulla, Jr. is likely to prevail on the merits, notwithstanding any of the aforementioned documents.

  1. 61.Horowitz and Kane are therefore, once again, forced to acquire attorney representation to defeat Mr. Sulla, as they are ignorant and incompetent pursuant civil procedures; and the Court does not respect common law that says Propria Persona pleadings are to be considered without regard to technicalities, since Propria pleadings are not to be held to the same high standards of perfection as practicing lawyers. See Haines v. Kerner 92 Sct 594, also See Power 914 F2d 1459 (11th Cir1990); also See Hulsey v. Ownes 63 F3d 354 (5th Cir 1995); also See In Re: HALL v. BELLMON 935 F.2d 1106 (10th Cir. 1991); but the Strance Court has been ruling otherwise.

  1. 62.On January 23, 2013, the Hawaii Court of Appeals, in No. 30295, rule that Sulla, Jr. and Hester had not won anything, and pursuant the $200,000.00 vacated jury award, sent the case back to the Third Circuit Court to judge the matter of fraud in the sale of the property by Lee to Horowitz with particularity. (See: APPEALS COURT RULING JAN. 23, 2013.pdf.

  1. 63.At the time of this writing the Ibarra Court has taken this matter “under advisement” following a hearing on Horowitz’s Motion to Void or Amend Final Judgments Due to Fraud Upon the Court, and Order Declaratory Relief by the Ibarra Court to Quiet Title. April 25 2013 w:Exhibits.pdf)

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