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Administrative Motion, case number 3:16-cv-07414-LB

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Tatyana Evgenievna Drevaleva

3015 Clement St., Apt. 204

San Francisco, CA, 94121

415-806-9864, tdrevaleva@gmail.com

Plaintiff in Pro Per

THE U.S. DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

 Tatyana E. Drevaleva

 Plaintiff,

 vs.

1) Alameda Health System

2) Officers of the California Department 

of Industrial Relations, the Division of 

Labor Standards Enforcement

a) Ms. Catherine Daly

b) Ms. Joan Healy

c) Mr. Bobit Santos

d) Mr. Eric Rood

 Defendants

 

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 Case Number: 3:16-cv-07414-LB

 Administrative Motion to Transfer my

 Lawsuit No. 3:16-cv-07414-LB

 to the Hon. District Judge James Donato;

 the Civil Local Rule 7-11;

 Declaration; Proposed Order.

 Location: Courtroom B – 15th Floor

 Judge: The Hon. Judge Laurel Beeler

Case 3:16-cv-07414-LB Document 112 Filed 08/30/20 Page 1 of 5
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Administrative Motion, case number 3:16-cv-07414-LB

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Plaintiff Tatyana Drevaleva is filing an Administrative Motion to transfer my lawsuit No. 

3:16-cv-07414-LB to the Honorable District Judge James Donato. Because a lawsuit No. 3:20-

cv-00642-JD is currently pending against the Hon. Judge Laurel Beeler, she is definitely 

ineligible to continue judging my lawsuit No. 3:16-cv-07414-LB.

During the litigation of the lawsuit No. 3:16-cv-07414-LB, the Hon. Judge Laurel Beeler 

expressed bias and prejudice towards me because I am a Pro Se penniless Russian Plaintiff, and I 

am not a lawyer. Ms. Beeler never invited the Parties to her Courtroom, improperly continued 

the Case Management Conference, banned Discovery, denied my May 16, 2017 Administrative 

Motion where I asked Defendant Alameda Health System to present the evidence that it was a 

Public Agency, and recklessly ignored the fact that three out of four DIR’s Officers Ms. Daly, 

Ms. Healy, and Mr. Rood were never served with a Summons and an Amended Complaint. In 

her July 07, 2017 Order, page 2, Ms. Beeler lied that these Defendants had waived the service of 

the Summons whereas they didn’t waive it. Ms. Beeler also never ruled on my Request for Entry 

of Default against Mr. Bobit Santos who was served with the Summons and the Amended 

Complaint but who missed a deadline to submit his response, who was not incapacitated, and 

who was not in the military. Ms. Beeler also never bothered to obtain any piece of evidence that 

would support DIR’s Officers’ claim of the “absolute immunity” pursuant to Government Code 

Section 820.2 and the “absolute privilege” pursuant to Civil Code Section 47(a.)

In her June 07, 2017 Order, Ms. Beeler ruled that the District Court didn’t have both the 

subject-matter jurisdiction and the Diversity of Citizenship jurisdiction over “Public Agency” 

Alameda Health System. Ms. Beeler recklessly ignored my May 16, 2017 Administrative Motion 

(Doc. No. 54) where I requested AHS to provide the proof that it was a Public Agency. On May 

16, 2017, Ms. Beeler continued the Case Management Conference to July 27, 2017 (Doc. No. 

53) but she abruptly entered a Judgment on July 07, 2017 (Doc. No. 77) thus depriving me my 

right to conduct Discovery and to obtain the pieces of evidence that could support my case. In 

both June 07 (Doc. No. 58) and July 07, 2017 (Doc. No. 76) Orders, Ms. Beeler impartially ruled 

in favor of rich Opposing Parties Officers of DIR and AHS. Subsequently, Ms. Beeler named my 

Appeal No. 17-16382 frivolous and revoked my IFP status on that Appeal. Doing all of this, Ms. 

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Administrative Motion, case number 3:16-cv-07414-LB

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Beeler didn’t think whether I would ever have a chance to work in my professional field as a 

Monitor Technician. She didn’t care about me. This is why I filed a lawsuit against her.

After the 9th Circuit reinstated my IFP status on Appeal No. 17-16382, I obtained the 

pieces of evidence that supported my claim against both AHS and DIR. I filed all these pieces of 

evidence with the 9th Circuit, and I filed a few Motions to Supplement the Record on Appeal. 

Defendants AHS and DIR’s Officers opposed my Motions stating that these pieces of evidence 

had not been presented to the District Court. The 9th Circuit sided with Defendants and denied 

almost all my Motions to Supplement the Record on Appeal (Exhibit 3.) As a result, the 9th

Circuit didn’t accept the critical pieces of evidence that supported my position. On December 24, 

2019, a 3 Judge Panel (Paez, Rawlinson, and Huck) affirmed the fraudulent Orders of Ms. Beeler

(Exhibit 4.) Subsequently, the Panel denied my Petition for Panel Rehearing and a Petition for 

Rehearing En Banc. The Panel concluded that my Petition for Rehearing En Banc was untimely 

even though I filed it in five days after the Panel denied my Petition for Panel Rehearing. On 

March 05, 2020, I petitioned to Chief Justice of the 9th Circuit the Hon. Sidney Thomas who is 

also an En Banc Coordinator, and I asked him to extend the deadline for filing a Petition for 

Rehearing En Banc pursuant to the General Order No. 5(b)(2) – “The En Banc Coordinator shall 

supervise the en banc process, including time schedules provided in this Chapter; shall circulate 

periodic reports on the status of each case under en banc consideration; may, for good cause, 

extend, suspend, or compress the time schedules provided in this Chapter; may designate 

another judge to perform all or part of the En Banc Coordinator's duties during the coordinator's 

absence; may suggest, for any particular case, a modification or suspension of the provisions of 

this Chapter; and may for good cause suspend en banc proceedings.” Subsequently, I submitted 

two more Letters to Justice Thomas on April 11, 2020 and on May 20, 2020. I never heard from 

Justice Thomas who was probably more concerned taking care of rich clients rather than to pay 

attention to a penniless Pro Se Russian Plaintiff who was thrown out of her job and who was 

suffering for many years from the absence of money.

On May 18, 2020, the U.S. Supreme Court denied my Petition for Writ of Certiorari No. 

19-8012. On August 03, 2020, the U.S. Supreme Court denied my Petition for Rehearing. Well, 

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Administrative Motion, case number 3:16-cv-07414-LB

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the high Justices also don’t want to be bothered by a Russian homeless and penniless Plaintiff 

who was fired for asking questions about unpaid salary, missed breaks, unsafe working 

conditions, and the denial of the affiliation to the Union.

The fact that the U.S. Supreme Court denied my both Petition for Writ of Certiorari and 

my Petition for Rehearing means only that the U.S. Supreme Court refused to accept the case.

See Exhibit 1 which is a separate page from the U.S. Supreme Court’s guidance to Pro Se 

litigants, “The primary concern of the Supreme Court is not to correct errors in lower court 

decisions, but to decide cases presenting issues of importance beyond the particular facts and 

parties involved. The Court grants and hears argument in only about 1% of the cases that are 

filed each Term. The vast majority of petitions are simply denied by the Court without comment 

or explanation. The denial of a petition for a writ of certiorari signifies only that the Court 

has chosen not to accept the case for review and does not express the Court’s view of the 

merits of the case.”

Moreover, see Rule 10 of the Rules of the U.S. Supreme Court, “Review on a writ of 

certiorari is not a matter of right, but of judicial discretion. ... A petition for a writ of certiorari is 

rarely granted when the asserted error consists of erroneous factual findings or the 

misapplication of a properly stated rule of law.”

Because the July 07, 2017 Judgment of the District Court and the December 24, 2019 

Memorandum of the 9th Circuit were based on erroneous factual findings and on misapplications 

of properly stated rules and laws, my intention is to file a Motion to Vacate the Judgment 

pursuant to the F.R.C.P. Rule 60.

Conclusion.

I am respectfully asking the Hon. Judge Laurel Beeler to transfer my case No. 3:16-cv07414-LB to the Hon. District Judge James Donato for a further proceeding. Ms. Beeler is 

ineligible to judge the lawsuit No 3:16-cv-07414-LB because a lawsuit No. 3:20-cv-00642-JD is 

lending against her. 

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Administrative Motion, case number 3:16-cv-07414-LB

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Prior to filing this Administrative Motion, I attempted to meet and confer with 

Defendants’ Attorneys Mr. Nicholas Seitz and Mr. Timothy Travelstead. On August 20, 2020, I 

emailed both Mr. Seitz and Mr. Travelstead with a proposal to transfer my lawsuit No. 3:16-cv07414-LB to the Hon. Judge James Donato (Exhibit 2.) I never heard back from both of them.

I declare under the penalty of perjury and under both the Federal laws and under the laws 

of the State of California that all foregoing is true and correct. Executed at San Francisco, CA on 

August 30, 2020.

Respectfully submitted,

Date: August 30, 2020. Sign Name: 

Print Name: Tatyana E. Drevaleva

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