Rocklin, CA, 95765 916.626.2831 Self-represented, Private Citizen COURT OF APPEAL,3rd APPELLATE DISTRICT STATE OF CALIFORNIA Plaintiffs ( NOONAN and BARNETT v. Defendant BOWEN et al Case: C071764 MOTION TO AUGMENT RECORD ON APPEAL (VERIFICATION DOCUMENTS ATTACHED) Pursuant to Rule 8.155(a) ofthe California Rules of Court, I, (11), request augmentation of the record on appeal to include documents in this case that were not included in the Joint Appendix and are material to Plaintiffs' Reply Briefs. Copies of the documents to be added to the record are attached to this motion. Those documents are: Verifications ofEDWARD NOONAN AND PAMELA BARNETT for the FIRST AMENDED PREROGATIVE WRIT OF MANDATE AND RESTRAINT OF FUNDRAISING. Plaintiff is requesting that these documents be added to the record because these are pages missing from the APPELLANTS' APPENDIX I declare under penalty of perjury under the laws of California that the foregoing is true and correct. Executed at Lincoln, California this 4th day of October, 2013 .
n .... Ir,..,.......""'Agent MPeulJ1VT" PAMELA BARNETT Agent 2351 Sunset Blvd., Ste. 170-921 Rocklin, CA, 95765 916.626.2831 Self-represented, Private Citizen COURT OF APPEAL, 3rd APPELLATE DISTRICT STATE OF CALIFORNIA Plaintiffs NOONAN and BARNETT v. (JoA.Jl)eflllIT ) Defendant ( f<--<- BOWEN etal Case: C071764 MOTION TO AUGMENT RECORD ON APPEAL MEMORANDUM OF POINTS AND AUTHORITIES (VERIFICATION DOCUMENTS ATTACHED) Rule 8.155(a) of California Rules of Court permits the augmentation of the appellate Record. In this case, the Verification pages for Appellants are missing from the First Amended Prerogative Writ of Mandate and Restraint of Fundraising. The need for augmentation here is compelling, these verifications were missing in the APPELLANTS' Appendix, therefore the record is incomplete. Not only is augmentation necessary, it will not prejudice any party. The augmentation request concerns documents which were part of the lower court record. Additionally, the augmentation will not cause a substantial delay in this appeal. CONCLUSION For the above reasons, this Court should order the record to be augmented on appeal by including the Verifications of Appellants NOONAN and BARNETT in support of the First Amended Prerogative Writ of Mandate and Restraint of Fundraising which are attached to this motion. Respectfully Submitted, Placer County, California PAMELA BARNETT Agent 2351 Sunset Blvd., Ste. 170-921 Rocklin, CA, 95765 916.626.2831 Self-represented, Private Citizen COURT OF APPEAL, 3rd APPELLATE DISTRICT STATE OF CALIFORNIA Plaintiffs NOONAN and BARNETT v. Defendant BOWEN et al Case: C071764 DECLARATION IN SUPPORT OF MOTION TO AUGMENT RECORD ON APPEAL APPELLANT BARNETT declares and states as follows: I am a self-represented litigant. APPELLANT requests court to approve MOTION TO AUGMENT RECORD ON APPEAL (Verifications) as the Verifications of APPELLANTS for the First Amended Prerogative Writ of Mandate are missing from the APPELLANTS' APPENDIX and are a necessary element for the record on appeal. Because the documents requested are attached to this motion, there will be no significant delay. I know of no prejudice to any party as a result ofthe granting of this motion. This motion is made in good faith for the reasons set forth above and not for the purposes of delay. I declare under penalty of perjury that the foregoing is true and correct. Respectfully Submitted, LA BARNETI, AGENT A- ppgL.L-!tt'J"l"" Placer County, California . : ~ , DECLARATION OFOMITTED VERIFICATION FORTHE FIRST AMENDED. qREROGATIVE WRIT OF MANDATE andRESTRAINT OF FUND RAISING ) CaseNo.34-2012-80001048 ) ) ) ) ) ) ) ) ) ) } ) } ) ) V. Respondents. SUPERIOR COURT OFCALIFORNIA _.. ... _....... l ~ _ .._.._ ..x DECLARATION OFOMITTEDVERIFICATION OFFIRSTAMENDED PETITIONfor PREROGATIVEWRITOFMANDATE AND RESTRAINT OFFUNDRAISING COUNTY OFSACRAMENTO Edward C. Noonan, Pamela Barnett, Sharon Chickering, George Miller, Tony oorz. NeilTurner, GaryWilmott Petitioners, Debra Bowen individually andofficial1y as The California secretary of State Barack Hussein Obama II; OBAMA FOR AMERICA CALIFORNIA ; John andJane Does andXYZ Entities. I, Edward C. Noonan. petitioner, decfare as follows, that the attached Verification was inadvertently omittedfromthefilingof theFirstAmended Prerogative Writ of Mandate andRestraint of Fundraising. I declare underperjury under the laws of California that theforegoing is trueand correct. DATED: I.Jl.,II S I!aJ/.SUCalifornia April l'J.-.-, 2012 Edward C. Noonan, Pamela Barnett, SharonChickering, George Miller, Tony Dob, Neil Turner, Gary Wdmott All ProSe, SelfRepresented Petitioners AdHoc California registeredvoters withserviceat 1713 rrth Avenue Olivehurst, CA95961 Telephone: 530-845-5186 33 35 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 36 37 38 39 40 41 42 Accordingly. I, PAMELABARNETT. beingdulysworn, deposeandsay under penalty of perjuryunder the lawsof theStateof California: That I ama petitionerself represented withoutbeingan attorney, over 21 yearsof agewithplacefor serviceat 171311thAvenue Olivehurst, CA95961. 1 2 3 4 5 6 7 8 9 10 11 VERIFICATION STATE OFCALIFORNIA COUNTY OFeIa.,cef?:.. ) ) 55. ) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 21 28 29 30 31 32 13 I havereadthe petitioners' First Amended Prerogative Writ of MandateandRestraint of Fundraising of the California Secretary of State(SOS) to bar ballot accessof ineligible declared candidatesfor officeof President of the UnitedStates(POlUS) at the 2012election cycle withrestraint of fundraising of such committees as a matterof imminentharmand irreparableinjUry withtimeas the essence, and I knowits contents; the factsstatedare trueto my ownpersonal knowledge, except as to the matters therein stated to beallegedon information and belief, and asto those mattersI believeit to be true. Thegroundsof my beliefsas to all matters not stateduponinformation andbelief areas follows: 3,d parties. booksand records, and personal knowledge except as to Swom.10 beforeme This12: day of January2012 CYNTHIA Y. OECOURTEN Commission II 1913276 ~ .... Notary Public California ~ z f ~ Placer County ~ J ".' Ml Comm. Expires Dec 12. 20141 ......... , . APP-009 PROOF OF SERVICE (Court of Appeal) FOR COURTUSE ONLY Mail o Personal Service Notice: This form may be used to provide proof that a document has been served in a proceeding in the Court of Appeal. Please read Information Sheet for Proof of Service (Court of Appeal) (form APP-009-INFO) before completing this form. Case Name:. <S00t 6 "'"'tJev U' 0 Court of Appeal Case Number: CO"I ? 6 'I Superior Court Case Number: 3'1go) ;;)-f?OOOIO'lf{CVW (Y'fOPj 1. At the time of service I was at least 18 years of age and not a party to this legal action. 2. My 0 residence [K] business address is (specify): S?liJ 41G-J5ed.-n ParI< 1Jnv& L/I)C-o//} Cfi '7Sf.:, iff! 3. I mailed or personally delivered a copy of the following document as indicated below (fill in the name of the document you mailed or delivered and complete either a or b): fY'.O o IV 7(;> !"I-V me,v-t', () EG(./f!.-rJ.//y'C'/O/V I /V"fiJ"M-O!?'14,vvI{)Vn,,-, a. Mail. I mailed a copy of the document identified above as follows: (1) I enclosed a copy of the document identified above in an envelope or envelopes and (a) deposited the sealed envelope(s) with the U.S. Postal Service, with the postage fully prepaid. (b) 0 placed the envelope(s) for collection and mailing on the date and at the place shown in items below, following our ordinary business practices. I am readily familiar with this business's practice of collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope(s) with postage fully prepaid. (2) Date mailed: /0/s-) 3 (3) The envelope was or envelopes were addressed as follows: IX/,vc.i'\) (a) Person servec(06A-f1'>p..-..0(3 f}-(J'1,1}- R>t:- f+lJ"eRIcr+) c:{U 0 (l) . Cl:Lep-,4LtC cc/oocu-e e- Bq, U,5 JvS""cp.
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II ress: . /.1 I l.--rr I 6+e, ;;J..;>OO '. 900;;1. 'I I C0$ Lfl-J (b) Person served: (DC;:: 6f<-A- 8 De...u.t:CfV) e'5t:J. (i) Name: Prr'"'\i-hofl""1 lf1'J-/<..C.a:c, 1 (ii) Address: p'(j) to I C/J, (c) Person served: CL--ff'P- F:- (i) Name: ;:5c-cca-e-...\.fo (ii) Address: ?d- 0 C( t-'h. -5 a C o -Additiotial persons served are listed on the attached page (write "APP-009, Item 3a" at the top of the page). Page 1 of2 www.courtinfo.ca.gov PROOF OF SERVICE (Court of Appeal) (4) I am a resident of or employed in the county where the mailing OCCUrred. The document was mailed from (city and state): FormApprovedfor Optional Use Judicial Council of CaIWomia APP-009[NewJanuary 1, 2009] APP009 3. b. 0 Personal delivery. I personally delivered a copy of the document identified above as follows: (1) Person served: (a) Name: (b) Address where delivered: (c) Date delivered: (d) Time delivered: (2) Person served: (a) Name: (b) Address where delivered: (c) Date delivered: (d) Time delivered: (3) Person served: (a) Name: (b) Address where delivered: (c) Date delivered: (d) Time delivered: o Names and addresses of additional persons served and delivery dates and times are listed on the attached page (write "APP-009, Item 3b" at the top of the page). RSON COMPLETING THIS FORM) APP-009 [New January 1, 2009] PROOF OF SERVICE (Court of Appeal) Page 20f2