Exhibit C-2 (3/20/24) CJP Complaint on Judge Clover (The Vernon Patterson Dossier)

This complaint alleges that Judge Suzette Clover participated in a pattern of judicial conduct that enabled constitutional violations by public defenders and the prosecution in People v. Michael Taylor (GA111132). The complaint documents how her courtroom facilitated the sale of the defendant’s vehicle—key evidentiary property—without proper notice, while the court simultaneously imposed bail restrictions that made retrieving that notice impossible. This directly implicates Exhibits A-4 (judicially-created obstructions to due process), A-7 (selective prosecution), and A-9 (abuse of bail and liberty conditions). Further, by presiding over proceedings where ineffective public defenders (Exhibits B-1 through B-7) were allowed to declare conflicts of interest without record or rationale, Judge Clover's courtroom became an instrument of due process erosion. The complaint highlights how Clover’s failure to address pretrial suppression, discriminatory charging, and prosecutorial misconduct supports constructive ratification of ineffective assistance. The judge's courtroom was used as a shield against remedy while defendants were misdirected into competency proceedings—a recurring theme in A-3, A-8, and B-5. This complaint reinforces that constitutional violations were both known and permitted by a sitting judge, demanding CJP accountability and further oversight.

Download This Complaint 

COMPLAINT BY MICHAEL TAYLOR ON JUDGE SUZETTE LOUISE CLOVER

Court acted in concert with prosecution and public defenders office in selling defendant's vehicle without proper notice while it is evidence in the case against him. The judge revoking the defendant's driving privileges as a condition of bail prevented the defendant from accessing his mailbox to receive any such notice as driving was his primary method for income and his vehicle was registered to a business he owns in another state. Public defender did inform the court of the defendant's need to operate a vehicle for work, however, they neglected to mention that the driving revocation bail condition would prevent defendant from accessing his own mailbox to receive such notice in event his property would be released for sale/auction while case is still pending. Furthermore, the defendant's lawyers persistent refusal to preserve their client's constitutional rights on the record against his wishes and better judgment in respects to any potential discrimination or unfair treatment in the application of law against him has prejudiced the defendant and is leading to a potential unjust outcome and an obvious presumption of guilt. Late in pretrial, the court failing to address the crimes committed against the defendant is an endorsing violation of the defendant's constitutional rights to due process and equal protection under the law. The court is attempting to hold the victim criminally liable in order to justify his attacker's civil injury claim by omitting obvious inferences and establishing a false premise of the case. The obvious criminal and malicious attacks against the defendant have not yet been addressed or lawfully justified at any point during this case. This complaint is being made in an effort to preserve the defendant's rights and raising concerns of potential discrimination in the charges against him because his public defenders have failed to raise such concerns since arraignment and preliminary. Department F in Pasadena Superior Court is presuming criminals, who were caught on video violating public safety and maliciously attacking another citizen, innocent while the speculative charges against the defendant is resulting in a high disparate impact. Prosecutor has failed to meet the burden of proof and has also neglected to clarify how charges against the defendant are consistent with the common government interest of protecting public order and safety. These charges are basically saying that the defendant's attackers had a legal right to physically harm another citizen, that it is ok to respond with violence to minor traffic infractions, or that because it happened in Glendale, CA and defendant's attackers were Armenian, the defendant should be held accountable and treated with implicit bias. Prosecutorial discretion should not be used to exercise a selective prosecution. Either you charge all 3 parties involved, or charges against defendant MUST be dropped. Otherwise, you are violating the defendant's right to due process and equal protection under the law. You cannot hold victims exclusively & criminally liable for their attacker's reckless negligence especially when the victim wasn't already involved in any criminal activity prior to time of incident. Prosecution and Glendale Police Department are conspiring against defendant to protect criminals who's activities are not constitutionally protected, while misusing resources and diverting attention from their actions to prejudice the defendant of a fair defense. If it wasn't already enough that the defendant can't afford private counsel, why must pleas for his constitutional rights under the law be inhibited by officers of the court? Instead, defendant's lawyers have spent extended amounts of time and county resources on doctors to examine their own client instead of challenging the prosecutor on their discriminatory charges against him. This represents a clear conflict of interest, denying the defendant a zealous defense due to the influence of public counsel having other cases against same prosecutors in the same court rooms with the same judges. This conflict of interest has resulted in ineffective assistance leading to a severe straining of defendant's access to adequate housing, gainful employment, and personal and professional relationships while out on bail. Further, public defenders office has made constant attempts to sabotage defendant's defense by arguing facts before the trier of law, omitting crucial details in his motions to dismiss, and constantly failing to address or challenge any potential discrimination in the charges against their client on the record. The LA County Public Defender has encouraged and insisted defendant to make uninformed decisions in court and has changed his diversion strategy from FASD to competency as a way to avoid having to defend, uphold, or remedy any potential violations of the defendant's constitutional rights. The LA County Public Defender has declared 3 consecutive conflicts of interest without reason or just cause in direct response to the defendant asserting his constitutional rights. Now, defendant is subject to severe consequences if he receives a failed 2nd opinion before his constitutional rights are protected. Defendant was not informed by defense counsel Ms. Daroca-Bell about the nature, results, or potential consequences of the expert witness doctor report before coercing defendant into accepting mental health court while neglecting to remedy violations of his constitutional rights. Not only is this an adverse action against the defendant, but it shows the public defender trying to cover their tracks for incompetence. Defendant has begged and pleaded for the ability and opportunity to assert his constitutional rights and challenging evidence as revealed in email communications. Public defenders have used attorney-client privilege to manipulate their client out of asserting their constitutional rights in favor of plea agreements that are against the best interest of defendants. These unethical and unprofessional behaviors by the LA County Public Defender has evolved into a compounding violations against the defendant's constitutional rights. All the defendant ever requested was for due process and equal justice under the law which was and always has been well within the scope of a lawyer's duties and obligations to their client. The defendant's request to assert his constitutional rights in court is and always was a reasonable request. As it stands, I have been subjected to a mental health evaluation against my will and interests while my constitutional rights have still not been upheld going on almost 3 years now! Just because I might be an indigent defendant does not mean I don't have access to the constitutional rights I was born with. Please help!

Download This Complaint