72 -1 ccfc stuart declaration in support of reply to mtn to strike
TRANSCRIPT
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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-1-STUART DEC ISO REPLY ISO
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Colbern C. Stuart IIIEmail: [email protected] Pacific Highway Ste. 102San Diego, CA 92110Telephone: 858-504-0171Facsimile: 619-231-9143In Pro Se
Dean Browning Webb (pro hac vice pending)Email: [email protected] Offices of Dean Browning Webb515 E 39th St.Vancouver, WA 98663-2240Telephone: 503-629-2176
Attorney for Plaintiffs California Coalition for Families and Children, PBC, andLexevia, PC
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
CALIFORNIA COALITION FORFAMILIES AND CHILDREN, et al.
Plaintiffs,
v.
SAN DIEGO COUNTY BARASSOCIATION, et al,
Defendants.
Case No. 13cv1944-CAB-BLMJudge Cathy Ann Bencivengo
DECLARATION OF COLBERN C.STUART IN SUPPORT OF REPLY INSUPPORT OF MOTION TO STRIKEMATTER IN MOTION TO DISMISS
Date: December 19, 2013Time: 3:30 p.m.Courtroom:4C
ORAL ARGUMENT REQUESTEDSUBJECT TO COURT APPROVAL
Complaint Filed: August 20, 2013
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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I, Colbern Stuart, declare and state:
I am a Plaintiff in this action, President and founder of Plaintiff California
Coalition for Families and Children, PBC, and Chief Executive Officer of Lexevia,
PC. I have personal knowledge of the facts stated herein and if called to testify would
competently testify as follows:
I. Discovery Requested Pursuant to Fed.R.Civ.P 56(d):
If granted leave as requested in the Motion to Strike, I intend to conduct
discovery on the following issues and exhibits presented in Defendants Motion to
Dismiss:
A. Request for Judicial Notice (Dkt#16-2)
1. RJN Exhibit “A”: The foundation, facts, and circumstances relating to the
Declaration in Support of Arrest Warrant made by San Diego City Attorney’s Office
Deputy City Attorney Ms. Emily Garson attesting under oath to facts as follows:
a. That Deputy City Attorney Garson “read and reviewed” the contents of San
Diego City Police Department “official reports” containing 26 “obscene and
threatening emails” between Plaintiff Stuart and his ex-wife, Lynn Stuart,
apparently gathered in a misdemeanor criminal investigation;
b. The foundation, facts, and circumstances relating to the claim that based
upon the 26 “obscene and threatening” emails between Stuart threatening
messages via email despite criminal pending criminal action against him.” In
the Declaration Ms. Garson requested issuance of a warrant for Plaintiff’s
arrest based upon her sworn representations as to the criminal nature of the
“obscene and threatening” emails contained in the “official reports” of the San
Diego City Police Department. Ms. Garson’s execution of the same.
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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c. The foundation, facts, and circumstances relating to the April 6, 2010
signature of San Diego County Superior Court Judge Krauel, and the language
“Declaration read; probable cause to arrest found; warrant to issue”.
2. RJN Exhibit “B”: The foundation, facts, and circumstances relating to the
“Ex Parte Minutes” form (CRM-177) relating to a misdemeanor criminal case. The
form references issuance of a misdemeanor warrant and bears a stamp “Roger
Krauel”, is dated April 14, 2010, but bears no reference to the Garson Declaration,
does not identify for whom the warrant was issued, the scope of the warrant, and does
not identify any agency receiving a warrant.
a. The foundation, facts, and circumstances relating to the materiality or
pertinence of this exhibit to any issue in this litigation.
b. The foundation, facts, and circumstances relating to the claim in Defendants’
MTD based on this exhibit that after March 24, 2010, I “continued to send
obscene and threatening messages.”
c. The foundation, facts, and circumstances relating to the “file” referenced in
the Garson Declaration, which appears itself to contain allegations or evidence
relating to a San Diego City Police Department investigation or officer relating
to emails, further hearsay, containing “obscene and threatening” language, also
potentially hearsay.
Related Allegations in the MTD:
a. The foundation, facts, and circumstances relating to Defendants’
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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representations that “Contrary to his allegations, at the time of the seminar,
there was an outstanding warrant for Stuart’s arrest in connection with a
criminal action” (MTD 3:22), and that “Stuart was arrested pursuant to the
outstanding warrant” (MTD 4:3).
3. RJN Exhibits “D,” “F,” and “G”: Printouts of Internet Pages at
“http://members.calbar.org”, ”http://www.azbar.org”, and “www.nvbar.org:”
a. The foundation, facts, and circumstances relating to these printouts of pages
from internet websites purporting to reflect proceedings and matters within the
State Bars of California, Arizona, and Nevada.
b. The foundation, facts, and circumstances relating to Exhibit “D” insofar as
they contain the same misrepresentations contained in the Garson Declaration.
4. RJN Exhibit “E ”: Unsigned “Decision and Order of Inactive Enrollment”:
The foundation, facts, and circumstances relating to this document, which purports to
be evidence of state bar proceedings within the State Bar of Nevada, including all
testimony or evidence contained therein.
5. RJN Exhibit “H”: “Order Of Temporary Suspension”:
a. The foundation, facts, and circumstances relating to this document.
6. RJN Exhibits “C” and “I”:
a. The foundation of these documents.
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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B. Nesthus Declaration (Dkt#16-3)
For many of the same reasons, Plaintiff requests discovery relating to the
foundation, facts, and circumstances relating to Nesthus Declaration insofar as it
proffers evidence, testimony, foundation, or other matter, including but not limited to
the following:
1. The events by Ms. Nesthus’ after she became aware of the Complaint—
calling around to parties and counsel requesting withdrawal of the Complaint,
“demands” to “remove” home addresses from the on-file Complaint, hearsay
representations regarding Ms. Nesthus’ conversations with Mr. Webb about details of
his representation of Plaintiffs.
2. Her knowledge of any party’s involvement in the pattern of HARASSMENT
AND ABUSE identified in the Complaint and the Motion for Harassment Temporary
Restraining order (Compl. ¶¶ 188, 202, 203, 228, 276, 279-80, 294, 386-391; Dkt#4).
3. Her knowledge of the foundation, facts, and circumstances relating to All
Immunity Affirmative Defenses
4. The knowledge, or the knowledge of any Superior Court Defendant, of the
foundation, facts, and circumstances relating to MTD sections C, D, and E the
substantive affirmative defenses of absolute judicial and sovereign immunities. Such
defenses are evidentiary, and the foundations for them are the proper subjects for
discovery.
5. The foundation, facts, and circumstances relating to the letter dated August
23, 2013 from Ms. Kristine Nesthus, Court Counsel for Defendant Superior Court of
the County of San Diego (SCSDC), including Ms. Nesthus’ representation to write on
behalf of Defendants TRENTACOSTA, ALKSNE, WOHLFEIL, and SCHALL; that
she and/or one or more of the defendants she writes on behalf of have received the
Summons and VERIFIED COMPLAINT, and/or became aware of its existence in
this Court’s PACER electronic filing system and on the Internet. Ms. Nesthus’
objection to the VERIFIED COMPLAINT existing in such locations; Ms. Nesthus’
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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representation that she writes on behalf of other, unnamed parties which she variously
identifies as “other judicial officers of the Court” and “all defendants.”
6. The foundation, facts, and circumstances relating to Ms. Nesthus’ assertion
that publication of the VERIFIED COMPLAINT containing Defendants’ places of
residence is a violation of Cal. Gov’t C. § 6254.21(c)(A) and (E) (the “California
Public Records Act” or CPRA),
7. The foundation, facts, and circumstances relating to Ms. Nesthus’ demands
that I “IMMEDIATELY”
A. Remove “from the above websites, and the internet generally, any and all
information concerning the residential addresses and telephone numbers of the
aforementioned judges…”
B. Remove the same for “any other judicial officers of the Court;”
C. Remove the same from PACER “because the complaint is available on
PACER, Government Code section 6254.21 requires you to take immediate
steps to remove this information from PACER.” and
D. That “you are hereby advised that you are prohibited from further
transmitting this information ‘to any other person, business, or association,
through any other medium.”
8. The foundation, facts, and circumstances relating to Ms. Nesthus’ statement
that I “Be assured that the Court will take all necessary legal actions to remedy this
situation and ensure the safety of its judicial officers.”
9. The legal foundations for Ms. Nesthus’s demands above.
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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10. The foundation, facts, and circumstances relating to Ms. Nesthus’
understanding and interpretation of The California Government Code section cited
above and in Ms. Nesthus’ letter, Cal. Gov’t C. § 6254.21 purports to prohibit speech
based on content (the address and phone number of public officials), including its
constitutionality.
11. The factual and legal foundations and circumstances relating to Ms.
Nesthus’ assertion that her clients’ personal privacy interests as expressed in the
CPRA are superior to First Amendment rights regarding public officials.
12. The foundation, facts, and circumstances relating to Ms. Nesthus’ assertion
that the act of filing the COMPLAINT including the addresses of judges Trentacosta,
Wohlfeil, Alksne, and Schall “constitutes a serious threat to their safety as well as
their family members.”
13. The foundation, facts, and circumstances relating to any Defendants’
understanding of the validity, scope, and enforceability of the CPRA.
14. The legal foundation relating whether the CPRA proscription against
disclosure “on the internet” is the “least restrictive means” for protecting the privacy
interest asserted.
15. The foundation, facts, and circumstances relating to any assertion that the
address, telephone, and even email contact information for Judges Trentacosta,
Schall, Wohlfeil, and Alksne are not available from numerous sources, including the
county registrar of voters, online election campaign financing forms, online and hard-
copy phone books, public address databases, credit records, public campaign funding
filings, tax records, and a wide variety of other publically-available sources.
16. Ms. Nesthus’ knowledge, awareness, or participation in any events or
allegations in the Complaint, including but not limited to the STUART ASSAULT,
the HARASSEMENT AND ABUSE, the DUE COURSE OF JUSTICE.
17. All communications by Ms. Nethus with any party, counsel for any party,
any San Diego County Sheriffs’ Department officer or employee, or any other person
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relating to the events described in the Ex Parte Application for Emergency
Harassment Restraining Order.
18. The legal foundation, facts, and circumstances relating any Defendants’
understanding, awareness, enforcement, or communication relating to the Court’s
General Order 550.
19. Any alleged burdens on any defendant in the granting a HARASSMENT
TRO under 18 U.S.C. § 1514 on all parties are insignificant as Defendants have no
legitimate interest to further HARRASSMENT AND ABUSE and obstruction of the
DUE COURSE OF JUSTICE.
20. The entirety of Ms. Nesthus’ and any Defendant’s communications with
Mr. Webb, court personnel, as well as her other post-filing activities described in the
Nesthus Declaration and elsewhere, including her or any other entity’s involvement
or coordination of San Diego Sheriff’s Department Deputies and perhaps other
authorities to communicate with any entity to request that they alter the availability of
Plaintiff’s Complaint from any location.
D. Other Discovery
1. All facts and circumstances relating to any claim that The STUART
ASSAULT was “pursuant to warrant” or otherwise authorized under law.
2. All facts, documents, witnesses relating to allegations in the Complaint
relating to THE STUART ASSAULT, the STUART ASSAULT COORDINATORS,
SDCBA ENGAGEMENT, CHILLING, DDIJO Complaints I, II, the DOYNE INC
Complaints I-IV, the DUE COURSE OF JUSTICE, and each related Count or Claim
for Relief in the Complaint.
II. Lexevia’s Revival
A. I am the founder and Chief Executive Officer of Lexevia, PC. Due
substantially to the events described in the Complaint, Lexevia has been hobbled
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from operating as a going concern.
B. As a result of my failure to file a Statement of Information with the
Secretary of State in 2011, Lexevia’s corporate status was placed in suspension.
C. I am in process of curing that suspension. On November 28, 2013, I filed
the required Statement of Information. Ex. “A” hereto is a true and correct copy of
that document. On December 6, 2013, I filed a Petition to Revive with the Secretary
of State and Franchise Tax Board. Ex. “B” hereto is a true and correct copy of that
document. I believe that those documents are all that are required to revive Lexevia’s
status to good standing.
D. I am informed and believe that the process of revival takes the Secretary of
State and Franchise Tax Board some time to process. I am optimistic that I can
achieve revival of Lexevia by February 28, 2014. I continue to work diligently to
achieve this result.
III. Corporate Plaintiffs’ Counsel Mr. Dean Browning Webb
A. Dean Browning Webb is counsel for Lexevia, PC and California Coalition
for Families and Children, PBC (“Corporate Plaintiffs”). I retained his services in
connection with Corporate Plaintiffs in this litigation on or about August 1, 2013. He
agreed to represent both Corporate Plaintiffs, but advised he is not admitted to
practice in this District Court. We agreed that I would proceed to identify local
counsel admitted to this Court to sponsor Mr. Webb, whereupon Mr. Webb would
formally appear as litigation counsel.
B. Since hiring Mr. Webb, I have continued to work diligently to retain local
counsel in order to achieve Mr. Webb’s pro hac vice admission. However, because
of the conflict profile of this case and complex legal issues involved, there are a
limited number of firms capable of accepting representation as local counsel.
Further, CCFC’s litigation budget in this matter limits the pool of counsel who would
otherwise be willing to accept a local counsel engagement.
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C. I have personally contacted dozens of counsel, none of whom could
overcome the many challenges to reaching an agreement toward representation as
local counsel to sponsor Mr. Webb.
D. Mr. Webb’s ability to participate in this litigation has also been hindered by
Defendants’ actions. As detailed in the Ex Parte Application for a Temporary
Harassment Restraining Order (Dkt#4), Ms. Kristine Nesthus contacted Mr. Webb
shortly after she became aware of the filing of this action. Ms. Nesthus made certain
statements to Mr. Webb which Mr. Webb took to be accusations of wrongdoing
based upon his representation.
E. As a result, Mr. Webb’s ability to zealously advocate for the Corporate
Plaintiffs has been chilled, making the process of proceeding on behalf of the
Corporate Plaintiffs even more difficult.
F. I continue to pursue retention of local counsel on behalf of the Corporate
Plaintiffs, and am hopeful to achieve the same as expeditiously as possible.
G. Though I cannot appear as counsel or on behalf of any Corporate Plainitff,
as President and Chief Executive Officer of Lexevia, PC and California Coalition for
Families and Children, I respectfully request the Court’s permission to continue to
pursue local counsel to sponsor Mr. Webb, and permission to continue my efforts to
revive Lexevia’s corporate status as indicated above, without being dismissed from
the case while I do. Up achievement of these goals, Lexeiva and CCFC intend to
continue this litigation to pursue remedies for past injury and to protect and promote
the interests parents and children nationwide.
I declare under the penalty of perjury of the laws of the United States that the
foregoing is true and correct.
DATED: December 12, 2013 By: /s/
Co ern C. Stuart, III, Pres ent,California Coalition for Families andChildren, PBCin Pro Se
Colbern C. Stuart, III
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have
consented to electronic service are being served with a copy of this document via the
court's CM-ECF system per Federal Rule of Civil Procedure 5(b )(2)(E). Any other
counsel of record will be served by facsimile transmission and/or first class mail this
12th day of December, 2013.
By: /s/
Colbern C. Stuart, III, President,
California Coalition for Families and
Children, PBC
in Pro Se
Colbern C. Stuart, III
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California Coalition for Families and Children, et al v. San
Diego County Bar Association, USDC SDCA Case No.
Case No. 13cv1944-CAB-BLM
Declaration of Colbern C. Stuart
Exhibit A
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SState of California
Secretary of State
Statement of Information(Domestic Stock and Agricul tural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.If this is an amendment, see instructions.
IMPORTANT – READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1. CORPORATE NAME
2. CALIFORNIA CORPORATE NUMBERThis Space for Filing Use Only
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
3. If there have been any changes to the information contained in the last Statement of Information fil ed with the California Secretaryof State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY CITY
STATE ZIP CODE
6. MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE
7. EMAIL ADDRESS FOR RECEIVING STATUTORY NOTIFICATIONS
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specif
officer may be added; however, the preprinted titles on this form must not be altered.)
7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY STATE ZIP CODE
8. SECRETARY ADDRESS CITY STATE ZIP CODE
9. CHIEF FINANCIAL OFFICER/ ADDRESS CITY STATE ZIP CODE
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least on
director. Attach additional pages, if necessary.)
10. NAME ADDRESS CITY STATE ZIP CODE
11. NAME ADDRESS CITY STATE ZIP CODE
12. NAME ADDRESS CITY STATE ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent fo r Service of Process If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California streaddress, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA,IF AN INDIVIDUAL CITY STATE ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATICONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
DATE TYPE/PRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE
SI-200 (REV 01/2013) APPROVED BY SECRETARY OF STA
EV34288
FILEDIn the office of the Secretary of State
of the State of CaliforniaLEXEVIA, PC
NOV-28 2013
C3195397
4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
COLBERN C STUART 4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
COLBERN C STUART 4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
COLBERN STUART 4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
COLBERN C STUART 4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
[Note: The person designated as the corporation's agent MUST have agreed to act in that capacity prior to the designa
COLBERN C STUART
4891 PACIFIC HWY STE 102, SAN DIEGO, CA 92110
CALIFORNIA COALITION FOR FAMIL
11/28/2013 COLBERN C STUART CEO
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California Coalition for Families and Children, et al v. San
Diego County Bar Association, USDC SDCA Case No.
Case No. 13cv1944-CAB-BLM
Declaration of Colbern C. Stuart
Exhibit B
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STATE OF CALIFORNIAFRANCHISE TAX BOARD Notice Date:PO BOX 942857SACRAMENTO CA 94257-2021
Application for Certificate of Revivor – Corporation Entity Number:
FEIN:
SOS Number:
Before the California Franchise Tax Board
In the matter of the application for certificate of revivor of:
Entity Name:
Address:
I request relief from suspension or forfeiture for this entity
. I previously submitted or I am enclosing all required
payments, returns, or documents.
Print Name _____________________________________ Title ________________________________
Signature ______________________________________ Date ________________________________
Daytime Phone Number ___________________________
Those who can sign this application on behalf of an entity (domestic or foreign) include:
Any stockholder, creditor, member, general partner, or officer. Any person having an interest in relief from suspension or forfeiture.
Domestic entities can also have a majority of the surviving trustees or directors sign on their behalf.
FTB 3557 BC (REV 07-2013) 355747071371
San Diego, CA 921104891 Pacific Hwy Ste 102 C3195397Lexevia PC
Lexevia, PC
4891 Pacific Hwy Ste 102
Colbern Stuart President
12/3/13
San Diego CA 92110
858.504.0171
8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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8/13/2019 72 -1 CCFC Stuart Declaration In Support of Reply to Mtn to Strike
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STATE OF CALIFORNIA FRANCHISE TAX BOARD PO BOX 942857SACRAMENTO CA 94257-0540
Entity Status Letter
Date:
ESL ID:
According to our records, the following entity information is true and accurate as of the date of this letter.
Entity ID:
Entity Name:
1. The entity is in good standing with the Franchise Tax Board.
2. The entity is not in good standing with the Franchise Tax Board.
3. The entity is currently exempt from tax under Revenue and Taxation Code (R&TC) Section 23701
4. We do not have current information about the entity.
The above information does not necessarily reflect:
• The entity’s status with any other agency of the State of California, or other government agency.
• If the entity’s powers, rights, and privileges were suspended or forfeited at any time in the past, or the entitydid business in California at a time when it was not qualified or not registered to do business in California:o The status or voidability of any contracts made in California by the entity at a time when the entity was
suspended or forfeited (R&TC Sections 23304.1, 23304.5, 23305a, 23305.1).o For entities revived under R&TC Section 23305b, any time limitations on the revivor or limitation of the
functions that can be performed by the entity.
Internet and Telephone Assis tance
Website: ftb.ca.gov Telephone: 800.852.5711 from within the United States
916.845.6500 from outside the United StatesTTY/TDD: 800.822.6268 for persons with hearing or speech impairments
LEXEVIA PC
6887862313
12/9/2013
.