Questions for OAH
How do i provide video evidence
What heading information do i put on top of the pleading paper if I’m defending against a state agency
How do I file a cross-complaint?
How are witnesses presented through video conference
Motion to dismiss
Request preconference hearing
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– Forgot to abort current smog before starting new smog check on different car.
– bureau fails to show any motive. I make more money in one month, or even less than one month from my one of my accounts alone then the entire period from august 2021 to november 2022 that the bureau alleges that i clean-lugged these six vehicles. But even if these alleged six clean-plugged vehicles failed all i still would make the same 40 to 60 dollars per vehicle so there is absolutely no motive, financial or otherwise for me to pass these six vehicles in a fraudulent manner.
I smog on average 15 to 20 vehicles for AT&T alone in one month alone, for an average of a thousand dollars a month
19. If the bureau is alleging negligence then the bureau is negligent for failing to prevent the certificate from being issued. It is known to the bureau’s OIS software that the VIN numbers do not match, but the software makes no attempt to prevent the certificate from being issued. There is no attempt by the software to inform the technician through simple message on the screen, athat there is a VIN mismatch, before (or after) allowing the certificate to be issued.
Negligence on the part of the technician would be issuing the certificate even after being informed that the VIN numbers do not match, but the technician is never informed or notified of any such discrepancy
Failed to run undercover vehicles
No attempt to show intent
Accusations based on pure speculation.
Bureau is itself guilty of fraud
Equitable estoppel
Inconsistent with STAR Program
Failed to follow its own policies
If you think people can’t make an occasional error when performing a very repetitive task you’re not living in the real world.
I don’t have the luxury of working in a nice quiet climate-controlled office, as a smog technician i have to be outside all day long in a very busy, noisy environment where we are completely exposed to the elements.
Grueling 60 hour schedule - people who work more hours will tend to make more errors than people who work less hours.
In a perfect world cars would never break down or get check engine lights, and would always and there would never be any need for a smog inspection.
Why doesnt the bureau impose a fine on the automotive manufacturer every time one of their vehicles fails a smog check?
In a perfect world people would never be effected by stress, never be effected the symptoms of a disease or pandemic, never be effected by working six days a week, 10 hours a day. That would cause them to make an occasional error.
In a perfect world people never make any mistakes.