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April 29, 2024 letter to Tracey Kennedy
I'm falling asleep. This letter will be moved to its own page very soon.
Date: April 29, 2024
To: Tracey Kennedy of Sheppard-Mullin
CC: Robin Ann Banks aka Ooley aka Deleuze aka Johnson
CC: Other parties as explained below
Re: Ooley research and demand letters
A promise of an immediate State Bar filing in the event of certain conduct is included further down. This letter is therefore CC'd under separate cover to parties at Sheppard-Mullin in addition to Ms. Kennedy. The higher-ups may wish to decide whether or not conduct rules are going to be followed.
Unrelated point: In the interests of transparency, this letter and other materials from all sides will start to go online this week on the Tracey Kennedy and/or Robin Ooley case site. The website addresses are as follows:
tracey kennedy dot com
robin ooley dot org
1. Ooley research questions.
I'm aware of the California deadline for filing of a defamation action against Robin Ann Ooley [aka other names] and/or other parties who may be involved. Presently, there is an intention to serve Ms. Ooley with the initial defamation demand letter well ahead of the case filing deadline.
May I ask, for purposes related to litigation as well as other legitimate and reasonable purposes, if the Ms. Ooley who engaged in defamation and other torts is the one with Social Security Number 305-58-7408 ? Or does that SSN belong to Ronnie Banks and/or Ryan Deleuze?
This is confusing. All three people seem to share the SSN. I assume that records are garbled and the SSN doesn't belong to any of them. It's a false lead. But I have no way of knowing for sure, so excuse the question.
On the other hand, if there is a specific reason that any of these people show up, correctly or incorrectly, as sharing an SSN, that is somewhat interesting.
If 305-58-7408 does happen to belong to Robin Banks, was that SSN issued at age 3 in Indiana, thereby confirming birth or early childhood in that State?
Note: 305-58-7408 is confirmed to be a valid SSN. As any good data person should be able to tell you, somebody received this particular SSN in Indiana and 1967. So, that part is consistent. The age that the SSN implies is a little off, though. The recipient is believed to be approx. age 61 or above and Robin Ooley is only age 60 as of two weeks ago.
BTW If Robin sees this, Belated Happy Birthday. We're both in our 60s now. Do you remember the song "When I'm Sixty-Four" and how far off the year seemed?
Moving on, why does Robin's insurance license under the Ooley surname, number 788860, seem to have expired in 2022 ? Does she hold an active license under one of the other surnames? Or is license 788860 valid and was it properly renewed after all?
Is D.O.B. April 17, 1964 ? Is the appropriate address for legal service 2557 Comistas Drive, Walnut Creek, CA 94598 ? Note: The owner is Ooley Trust, so it seems to be a match.
Is the maiden name Banks [from mother Georgia Banks of Indiana decades ago] ? Are the surnames Deleuze, Johnson, and Ooley from marriages to John Deleuze, Bradley Johnson, and David Ooley?
If the maiden name is Banks, why does there seem to be a son named Alexander Banks? Wouldn't he take his father's surname? But he might be a nephew. And why is there a daughter, apparently, named Taylor Griffin? There is no way that Robin squeezed in four marriages total from her 20s to her 50s. Is Griffin a married name and is the actual name Taylor Ooley?
Regardless, what's the deal with three marriages in a row, children from two or three of them, and a State Farm practice throughout it all under two of the surnames, including a business partnership with an spouse or an ex as well as a sister? This is a busy lady and very much, it appears, a State Farm family.
The sister part isn't confirmed, though. Is Joline Banks, a State Farm agent of about my age who seems to share a street address with Robin, Robin's older sister? Is she the one who talked Robin into becoming an insurance agent?
Did the Banks family start out in or near Plainfield, IN ? Did growing up in Indiana, at least in the early years, influence Robin's perspective on right and wrong? On whether or not its appropriate to break the Ninth Commandment?
These questions are raised for legitimate and reasonable purposes. Please see part 2 below.
2. Fiduciary relationship issue.
Please note that I have no fiduciary relationship with Robin Ooley [aka other names] that imposes responsibilities on me under State or Federal laws in connection with the handling of protected or unprotected personal information. I largely need to be able to demonstrate legitimate and reasonable purposes.
I don't recommend that State Farm or Sheppard-Mullin make false claims or allegations related to the inclusion of such information in this letter.
I can, legally, and I will, for legitimate and reasonable purposes that are protected under U.S. laws, proceed in every legitimate and reasonable way to seek remedies for the torts and/or possible crimes that are believed to have been committed.
This will certainly include all possible documentation related to every party involved at all levels that may lead to evidence for litigation, hidden assets, street addresses for service, assistance to me by law enforcement, State Bar actions, the engagement of news media, writing in the public interest, and/or other legitimate and reasonable information goals.
In short, I have a boatload of legitimate and reasonable purposes.
To bully and make possibly illegal threats such as "Kiraly should be warned that Sheppard-Mullin is far more powerful" is what you do. Information is what I do. For 46 years now. Or 50 years depending on what's counted.
Oddly enough, 50 years is how long I've been a faithful client of State Farms.
Did I mention that I was the sole software developer for half of the U.S. Vote one year or how I qualified for that job? Or that I've worked on data for the DTIC, the CIA, UK-NCIS [anti-terrorism after 9/11], and the MILES project for Northrop-Grumman?
To be clear, I was never involved with the type of dramatic work that is on TV shows. I didn't jump between buildings or confront arms dealers. Physical exercise like that would have been healthier for me. But I just worked quietly with data for five decades. I was and I remain adequate at it. Do let me tell you another time how I earned the U.S. Vote position at a young age.
Note: I ran one level of the U.S. Vote [but just 50% of the data] before Diebold. I had nothing to do with any of what Diebold did. Diebold was a criminal enterprise and I don't respect or bow to criminals.
You may wish to relay that to Robin Banks Ooley Deleuze, to State Farm, and to the Sheppard-Mullin attorney who made a colorful threat that will be discussed further in due course.
One of you has talked to C. Long. You may have committed a crime in doing so, but never mind that right now. Why don't you ask that attorney to boast of how she's made me bow to the organized crime entity that she represents? Oh, wait. :-)
After you speak with Ms. Long, use the "far more powerful" resources that you mentioned in the likely illegal threat that you tried to relay to me. Look into my own legitimate and reasonable specialties that are entirely consistent with U.S. laws.
But don't cross State lines directly or indirectly if you decide to cross legal lines. I won't mind the chance to bring the FBI into this matter.
The FBI isn't going to be highly interested. I once reported a child kidnapping to them and they wouldn't touch the case because it was more of an ICE issue. This was the kidnapping of an infant out of the Philippines. [He is now an adult but his father doesn't know that he's still alive.] The FBI considered this case to be ICE's problem. But they did take action in another case.
For those of you who know who C. Long is, the kidnapping case led partly and indirectly to the matter that C. Long is involved in. I'd asked a P.I. to work with me on the kidnapping case. We tried to identify the victim's father. This was Fox TV's former Reality P.I. It's an odd story.
I owed the P.I. a favor. So, I did what I do with data. I proved for the P.I. that California's most cash-rich foundation was engaged in mass fraud.
Also, Tracey, that these people hated Blacks and considered them to be, quote, "smelly". But you'd be fine with silencing whistleblowers for such people, wouldn't you? No cognitive dissonance at all. Sure, why not.
Millionaires and their toys such as State Farm don't like whistleblowers. So, they came after me.
Just as Sheppard-Mullin hopes to do if the number of legitimate and reasonable emails that are received crosses some arbitrary threshold. But this matter will be high enough in Google by then that abuse of process is likely to backfire.
I think that I might get Streisand Effect this time. Feel free to Google the term. I've only managed to get Streisand Effect once before and that required a team of 6 people. But it's fun if one can make it happen. That was a heck of a day.
In the State Farm case, I might be able to do something instead with the fact that an IL-DOI agent has alleged that Michael Tipsord personally violated protocol in Illinois and this matter includes both CA and IL. Her supervisor has tried to tidy it up but I'll swear to what I was told. It seems like an inter-State matter and that might put it into the FBI's jurisdiction. We'll see.
You could phone some of the attorneys who threatened me inappropriately in the past 12 years. It might be interesting. You could ask them how it turned out. I'm not referring to the cases on the record. Would you like to speak with the attorneys who left their firms to avoid prosecution or other legitimate and reasonable consequences that were consistent with U.S. laws?
3. Another note about C. Long.
In February 2024, I mopped up the floor in Court with C. Long. One case remained [and remains]. In March, I sent C. Long a settlement offer for that case. It was 6 or 7 pages that explained in detail how much of a moron that attorney is. I listed her mistakes and what I'd do next in Court if she didn't go away. I said that she should give me $25K and then she should truck off.
I suppose that it wasn't a usual settlement letter.
Surprisingly, C. Long caved. She refused to give me the $25K but dropped all demands and asked to go away. I refused because you, Tracey, still hold the keys to ending the rape that your clients are so enthusiastically committing.
C. Long has interacted previously with your client[s] and/or you in a manner that I believe violated State and/or Federal laws. She revealed this in the February 2024 hearing that ended with her getting trucked in such a thorough manner.
If I can identify the party on your side who was involved, and if it was an attorney, I actually am going to try for their license. But the relevant part today is that the two cases are one. C. Long is going to talk to your client[s] and/or you to see if there is an exit for everybody. Or the final case on that side will continue for another year and I'll do my best to feed that attorney's career to her in delicious pieces.
Just as I'll try to do, in a legitimate and reasonable sense that is protected under U.S. laws, for some of the people involved in the State Farm manner. Which reminds me; I know that the part about Robin's license having expired in 2022 is probably a mistake. But do confirm this to save all of us some time. What license number *is* Robin practicing under?
In the unlikely event that C. Long agrees to contact your client[s] and/or you, my advice is that you work with her on this matter. Or, in a legitimate and reasonable sense that is protected under U.S. laws, this matter will continue for a decade and every step will go into a growing body of Google entries.
Don't tell your client[s] that you can get an RO that will include a broad gag order. Seriously.
4. Demand for allegations.
I've now reviewed such material as State Farm has chosen to provide in connection with the current matter. It appears that no, i.e., zero, specific and relevant allegations have been made against me. If I've missed something, feel free to let me know.
Sheppard-Mullin has cited emails allegedly sent by me *after* State Farm engaged in three or four torts and one or more possible prosecutable crimes to justify State Farm's conduct. Such emails can't be used ex post facto to justify the conduct.
I request and demand that the specific and relevant allegations against me be provided to me.
5. Immediate State Bar filing.
The promise of State Bar action is as follows. Recently, Sheppard-Mullin made an explicit and unambiguous attempt to relay a threat to me through an attorney who should not have been asked to listen to or relay the threat.
The threat is, in and of itself, a possible indication of a prosecutable crime on the part of parties at Sheppard-Mullin. However, set that aside for now and it remains a likely conduct violation for demands or threats to be sent to that attorney.
That attorney may communicate shortly with Sheppard-Mullin. If so, presently, it'll be under a limited scope arrangement. He'll explain to me the extent to which limited communication from him to Sheppard-Mullin will entitle your firm to send communications to him.
If the response to this letter is to communicate with that attorney prematurely, or with any attorney who does not formally represent me yet but who is asked to relay threats to me, a complaint to the State Bar will be filed within three business days.
It isn't expected that anybody will be disciplined. But the State Bar will be asked to keep the file open in anticipation of further thoroughly documented issues.
(end of document)
News:
One of Sheppard-Mullin's attorneys has stated to an attorney who doesn't presently represent me in the current matter that Sheppard-Mullin is a “far bigger and more powerful law firm than Berliner Cohen LLP.”. This was, of course, a threat, but that isn't the key point.
The key point is the wording of the threat. One of the most powerful law firms in the country has just demonstrated its likely intention to commit abuse of process.
What, exactly, is “far bigger and more powerful than Berliner Cohen LLP” supposed to mean? As Berliner Cohen LLP is “far bigger and more powerful” than me, Sheppard-Mullin isn't referring to a match of abilities to cite the law. The emphasis on the company's power and influence is about possible prosecutable crimes.
While we're at it, who, exactly, told Christine Long about the State Farm matter? She was aware of it and brought it up in a February 2024 hearing. Wasn't the matter supposed to be confidential until I brought it up myself? Did Tracey Kennedy or another party at Sheppard-Mullin violate rules or standards by discussing it?
As a related note, this site is now accessible as traceykennedy.com and susancappo.org as well as statefarm.meme and robinooley.org.
Other domains will be hooked up in due course. The single site will then be split up into multiple, more focused, individual sites.
This site does not represent State Farm, insurance agent Robin Ooley of State Farm, Robin Deleuze, Sheppard-Mullin, or presently any party other than the Old Coder, Robert Kiraly. Domain names are used under Fair Use, Nominative Use, and the provisions of ACPA. Trademark or other litigation related to domain names will be treated as malicious prosecution and/or barratry. Attorneys, see additional notes further down and on the notices page.
For contact information, privacy policy and other legal notices, click on the Contact and/or Notices buttons at the top of this page.
What is this site?
This is the start of a public interest site that will discuss misconduct and, in effect, a legal rape by State Farm insurance agents Robin Ooley and/or Susan Cappo and the roles that other parties have played in the matter.
It's an unusual story, but not unusual enough.
I've been told by insurance agents of 25 to 50 years experience that they've never heard of other agents committing the type of rape that Ooley and/or Cappo have committed. But the general principle of the wealthy going after hapless victims out of hatred of race or other discrimination or simply petty spite is all too common.
This site, or these sites, will review the factors that led the people involved to believe that they were entitled to commit what has amounted to a rape.
Other parties include:
State Farm General Counsel Steve McManus, who, according to his assistant Angie Peterson, a self-described “compassionate person”, is directly involved.
* State Farm Michael Tipsord. This part is interesting. An Illinois State Dept. of Insurance investigator has alleged directly to this writer that Tipsord personally involved himself in an IL-DOI investigation of the current matter. Whether it is true or false, it is a fact that an investigator has made the allegation.
* Robin Deleuze. This seems to be an alternate name for Robin Ooley but this isn't confirmed. There is a bit more in the Ooley background sketch further down.
* Sheppard-Mullin partner Tracey Kennedy.
* Investigators and General Counsel at CA-DOI. Details are to be filled in here.
* Frana Trana, a regional manager at State Farm who is alleged by insurance agents to play a key role.
and a cast of, well, a few dozen. Not really hundreds yet.
Hiring artists and others:
These sites are hiring illustrators to do illustrations of the characters and events that will be discussed. One children's book illustrator will be hired in addition to a usual illustrator.
These sites are also seeking to hire another P.I. and a publicist.
For contact information, click on the Contact button at the top of the page.
Note: If there is a phone number listed, do not leave voicemail as there is no voicemail. Text and identify yourself. Text messages without identification may be blocked.
Who are Robin Ooley and Susan Cappo?
First, no, none of this is protected information, intimate personal information, or cyberstalking. Attorneys: Allege anything of the sort and let's talk about barratry.
This is protected public interest disclosure and discussion related to likely violations of Unruh, ADA, and State and/or Federal rules and/or other guidelines of other types.
I *will* try for anti-SLAPPs if I'm sued and there is a chance of winning anti-SLAPPs. I've done two anti-SLAPPs so far and have learned from the process. It'll add up to the story spreading further regardless.
Robin Ooley is one of perhaps two people by that name in California. She's a successful insurance agent in Walnut Creek, California who sells State Farm policies.
Ms. Ooley seems to have the alternate name Robin Deleuze but this is unconfirmed. I believe that Deleuze may be a former surname by marriage but I haven't seen a marriage or divorce record about this. There are other possible surnames, Banks and Johnson, as discussed further down.
Robin's middle name might be “Ann” but this is unconfirmed.
Robin Ooley has stated on a State Farm website that she's been a “State Farm Agent since 1991”. She'd have been about 26 years old when starting and would have had about 33 years of experience as of 2024.
The age calculation is based on a presumed birth year of 1964. Robin seems to be a year older than my youngest brother, Scott. Note: The month of birth shows up as both April and November. Odd.
Education was a B.S., not just a B.A., at Ball State University. It might be the one in Indiana. I don't see her yet in alumni lists for that institution but she seems to have resided in both Muncie, IN, and Columbus, IN in the past. Note: The B.S. was in Nutrition.
Some sources refer to Robin Ooley as Robin Banks or Robin Johnson in addition to Robin Deleuze.
In an interesting note, Robin Ooley seems to be related to a Joline M. Banks who is, or was, also a State Farm agent.
Robin Ooley, Joline Banks, and a third State Farm agent named John G. Deleuze seem to have used the same phone number, (9X5) 946-9136, at one point. [I've partly redacted the phone number.]
This isn't too surprising because it could have been a shared office phone. However, some sources suggest that John and Robin may have been married in the past. This is unconfirmed and I don't know how Joline Banks fits into it.
Note: John G. Deleuze's State Farm website is located at:
One of the four surnames, Ooley, Deleuze, Banks, and Johnson, is probably the birth surname and the other three surnames would be marital. But which is which isn't clear yet.
By the way, yes, I certainly have the legal and ethical right to dig into the background factors that led Robin Ooley and/or her associate Susan Cappo to commit what amounts to a de facto rape and not a nice one.
Robin is supposedly associated with PHL Variable Life Insurance Company as well as State Farm. I haven't heard of PHL before but the firm seems to be in difficultuies.
Robin seems to claim to speak some Hindi and Spanish as well as English. This is unconfirmed.
We'll come back to Susan Cappo and her background and role in a remarkable crime and/or near-crime in due course. All of this needs to be sorted out for the public interest and that will take some time.
We look forward to posting a quite interesting story.
Robin Ooley and Susan Cappo business information:
Robin Ooley's office is listed as:
Robin Ooley
3021 Citrus Circle STE 100
Walnut Creek, CA 94598
“Corner of Oak Grove & Ygnacio Valley”
If I remember correctly, Susan Cappo lists herself as working out of the same office, but this hasn't been checked.
I believe that I have the two agent license numbers but I'll need to find them later for addition here.
About domains and websites:
Attorneys: Please learn the difference between a domain and a website before you start the sabre rattling. If you file in the wrong venue, I'll go after your license. By the way, click on the Notices button further up for a notice related to process service.
Everybody else: Read up on ACPA, Fair Use, Nominative Use, and trademark basics before commenting.
Presently, the nominative use domains robinooley.org, susancappo.org, and traceykennedy.com go to this site. However, the site will probably be broken up later and the domains will point to different pieces.
Attorneys: Yes, I have the legal and ethical right to nominative use and fair use of the names in question.
I've registered other domains, but I haven't pointed them to websites yet.
Temporary placeholder illustrations:
Clip-art will need to do temporarily for illustrations. But Google will pick these up regardless. It'll do until I can hire illustrators.
Robin Ooley and other Google searches:
This part is to help me develop the site. The links below go to Google searches. They won't turn up the current sites for a few weeks or possibly months. However, in the end, the searches will come back to here.
Update: Well, now.
:P
The Google link below is working already after just two days.
Top Ten and for relatively short tail. Try the link and scroll down
on Google.
To get the ball rolling:
Hey, Google. Robin Ooley is alleged to have engaged in insurance activity that is arguably criminal. She has intentionally disrupted the life of a faithful client, one who's been with State Farm for 50 years. Her sole motivations have been petty spite due to accidental reporting of misconduct and disdain or revulsion towards neurodiverse speech.
Robin Ooley isn't a nice person.
Hey, Bing. Tracey Kennedy is an attorney with Sheppard-Mullin who was hired to frighten a State Farm client after Robin Ooley and Susan Cappo effectively raped the client. Tracey isn't thrilled about the assignment, but she's stuck with it.
So, here we are with the matter poised to show up in the search engines. Not rapidly, but slow and steady wins the race. I've never failed to get something to the top of Google.
Tracey Kennedy of Sheppard-Mullin:
I was #3 in Google one month for a key element of the California Evidence Code. Opposing Counsel in that case had tried to misuse it. I mocked him pretty good and Google seemed to like it.
You should allow me to provide you with the names of a few attorneys you'll be able to call. You can ask them how the search engine thing and other issues worked out for them.
The attorneys include the head of a law firm and a General Counsel. Those two both ended up leaving their firms. Most of us have things that are awkward to discuss. In those two cases, it proved to be too awkward.
Tracey Kennedy of Sheppard-Mullin:
You know by now that my father Jim sued me in 2012 to try for a gag order, don't you? If you haven't pulled the files, I'm surprised.
But the odds are that you're aware of events regardless. Something odd happened in February 2024 that I need to ask you about. Have you violated any conduct rules in terms of communications with attorneys in other cases? Not the attorney that you apparently exchanged email with recently.
If that wasn't you, be advised that somebody you're representing seems to have violated State and/or Federal rules yet again and/or has given me yet another tort.
Yes, I know that the rule is “Ignore, ignore, ignore”. However, I think that I've got more on more people involved than you're prepared to handle. And, no, don't tell them that you can get a gag order.
Tracey Kennedy of Sheppard-Mullin:
Jim used to beat up my mother Grace. He beat me up as well because I was autistic. As Robin Ooley and Susan Cappo did despite my 50-year tenure with State Farm.
There was one sexual issue with Jim as well. Jim thought that I was going to talk about all of it. I'd never thought of doing so. I shoved the legal case up his assets. Then I sent 2,500 postcards which linked to a website.
I eventually got in the hundreds of thousands of uniques on the website. In Google, I got short tail. Ask any SEO friends that you have and they'll tell you, “Short tail is the best tail.”
A note for everybody:
What I'm saying is, it's usually best for all sides, aggrieved parties, CEOs, attorneys, anybody involved, to work out issues rather than have things come out as naturally happens in litigation.
To be clear, I dance with the skeletons in my own closet. It's remarkably liberating. There is nothing that you're going to be able to use yourself. Believe me, people have tried and it's gone up their assets every time.
And one of my skeletons is useful. I'm neurodiverse in a way that I'm able, in a sense, to see into the infrared in the context of patterns in data. People are made of data, you know. So are true statements and false ones.
Tracey Kennedy of Sheppard-Mullin:
None of this is a “boast”. Don't try to cite it as such in future litigation.
I spent two days in the Emergency Room and Urgent Care this week. I couldn't dress myself or type for a day. My mother is apparently dying as well. She's as old as dirt and a harpy besides, not a great loss, but, still. I need to have one of my P.I.s serve the caregivers with a wellness check demand letter. That is a distraction.
In short, I'm tired and not being pompous. And I'm not dancing with delight at the thought of needing to focus on another thread. But your clients have committed what amounts to a rape.
I have no idea yet of what these people are thinking but the optics are on my side in spades.
A note for everybody:
But, you know;
Get a clue and let wisdom ensue
Sue won't be billable dollars accrue
Dollars accrue, publicity rue, the advice isn't new
Get a clue and let wisdom ensue
Without wisdom you're a cow that says moo
Tracey Kennedy of Sheppard-Mullin:
You know that I have the legal and ethical right to write in the public interest about your own background, don't you? And that gag orders in what the Courts see as kerfuffles are essentially impossible, right?
Oh, one more thing for now. When Jim tried for a gag order — this was a 2012 to 2013 case — I commented to Opposing Counsel, a woman at that point, that Jim had so many skeletons in his closet, she was going to face embarrassment.
Opposing Counsel said, “You're talking in a threatening tone.”
I responded, “Actually, it's a 'promising' tone. And, by the way, are you able to spell barratry?”
Opposing Counsel dropped out and the case went to a more junior attorney. I was a Pro Per part of the time, but the replacement attorney ended up eating sh*t. Regardless of what you've been told about that case, there wasn't even a Court settlement. Instead, Jim ended up on the run from his past for the rest of his life.
The point is, use the phrase “threatening tone” in conjunction with anything that I've said and we're going to talk about the difference between an illegal “threat” and a “promise” that is protected under U.S. laws.
I should acknowledge that Opposing Counsel in 2012, the “threatening tone” woman, didn't drop out because I had a snappy rejoinder. She dropped out because I dug into the past, over 35 years, and actually came up with a witness who she knew could, excuse my French, f*ck her client and embarrass her to past the point of recovery.
Read the Feral Coder poem on this website, Tracey. Thank you for your time.
As a note to my associates, the surprise witness in 2012 was, of course, Twisted Time, the quadraplegic who ran a disability foundation. I'll probably put a link on this site to “The New Song for Twisted Time”.