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1 Colbern C. Stuart III Email: Cole.Stuart@Lexevia.com 2 4891 Pacific Highway Ste.

102 San Diego, CA 92110 3 Telephone: 858-504-0171 Facsimile: 619-231-9143 4 In Pro Se 5 Dean Browning Webb (pro hac vice pending) Email: ricoman1968@aol.com 6 Law Offices of Dean Browning Webb 515 E 39th St. 7 Vancouver, WA 98663-2240 Telephone: 503-629-2176 8 Attorney for Plaintiffs California Coalition for Families and Children, PBC. and 9 Lexevia, PC 10 11 12 13 CALIFORNIA COALITION FOR 14 FAMILIES AND CHILDREN, et al. 15 16 vs. Plaintiffs, DECLARATION OF COLBERN C. STUART IN SUPPORT OF MOTION FOR SANCTIONS UNDER F.R.C.P. RULE 11(b) Date: January 24, 2014 Time: 2:00 p.m. Courtroom: 4C ORAL ARGUMENT REQUESTED SUBJECT TO COURT APPROVAL Complaint Filed: August 20, 2013 Case No. 13cv1944-CAB-BLM Judge Cathy Ann Bencivengo UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

17 SAN DIEGO COUNTY BAR ASSOCIATION, a California 18 Corporation, et al, 19 20 21 22 23 24 25 26 27 28 I, Colbern Stuart, declare and state: Defendants.

I am a Plaintiff in this action, President and founder of Plaintiff California Coalition for Families and Children, PBC, and Lexevia, PC. I have personal

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1 knowledge of the facts stated herein and if called to testify would competently testify 2 as follows: 3 1. On September 30, 2013, I was served with Defendants Motion to Dismiss

4 Complaint, Request for Judicial Notice, Declaration of Kristine Nesthus, and Exhibits 5 thereto. 6 2. I have reviewed the Motion and conducted research in response to the issues

7 raised therein. My research indicated that the Motion to Dismiss is brought on 8 numerous irrelevant, inappropriate, and inadmissible grounds, arguments, and 9 evidence. 10 3. In order to address the motions breadth and misguided direction, I prepared

11 a detailed letter in an attempt to initiate meet and confer negotiations with Defendants 12 (M&C; Exhibit A to my declaration in support of the Opposition/Motion to 13 Strike). I delivered this letter on October 28, 2013. 14 4. Two days later, on October 30, 2013, Defendants summarily declined my

15 request to meet and confer or attempt further informal resolution. (Exhibit B to my 16 declaration in support of the Opposition/Motion to Strike). 17 5. Details of my education, legal publications, appearance in published cases,

18 state and federal court litigation trial and appellate experience, and relevant federal 19 Commercial, Consumer Fraud, Intellectual Property, and Civil Rights litigation 20 practices are provided at Compl. 102-106, and Exhibit 24 to the Complaint. 21 6. Additional details of my legal experience in practice areas relevant to this

22 lawsuit are available on Westlaw and Lexis as well as the following websites, 23 incorporated herein by reference: 24 25 26 27 28 http://www.ipfrontline.com/depts/article.aspx?id=17864&deptid=8; http://www.kattenlaw.com/Katten-Further-Expands-Intellectual-PropertyPractice-With-Addition-of-Robert-Breisblatt-as-Partner-in-Chicago-Office-0331-2008; www.lexevia.com; -2-

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www.linkedin.com/pub/cole-stuart/8/282/69b; http://investing.businessweek.com/research/stocks/private/person.asp?personId =43335717&privcapId=1660521&previousCapId=1660521&previousTitle=Ka tten%20Muchin%20Rosenman%20LLP; http://www.mediation.com/memberprofile/colbern--stuartiii-92130-91.aspx;

7. As an Intellectual Property practice area Partner at the law firm of Katten,

8 Muchin, and Rosenmans Los Angeles office, my regular hourly rate for such matters 9 as this in 2009 was $690 per hour. Rates for lawyers with experience similar to mine 10 at similar firms today are considerably higher. 11 8. As a consultant my current regular hourly rate today is $375.00 per hour for

12 commercial matters. I regularly handle civil rights matters on a discount or pro bono 13 basis. Examples of my recent civil rights work may be found at the following 14 websites, incorporated herein by reference: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 http://www.weightiermatter.com/; http://www.croixsdadsblog.wordpress.com/; https://www.facebook.com/CCFCONLINE; http://angiemedia.com/tag/colbern-stuart-iii/; http://www.thepubliccourt.com; http://citizensdemandingjustice.blogspot.com/2012/09/californiacoalition-for-families-and.html; https://plus.google.com/communities/102887458338487152591?cfem=1 http://www.leginfo.ca.gov/pub/11-12/bill/sen/sb_04510500/sb_472_cfa_20110425_114429_sen_comm.html; http://www.blogtalkradio.com/sdcommunitycoalition/2011/02/03/califor nia-coalition-for-families-and-children; http://www.thepubliccourt.com/; http://angiemedia.com/tag/california-coalition-for-families-andchildren/; -3-

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http://blip.tv/san-diego-county-community-coalition/victories-againstfamily-court-for-the-people-for-a-change-6170297 http://divorceinconnecticut.blogspot.com/2013/10/california-parentsfile-federal-rico.html; http://www.youtube.com/watch?v=cYoYRw8Uqc; 9. In reviewing the Motion to Dismiss Complaint, researching the issues raised

7 therein, preparing the M&C, Motion to Strike, Opposition to the Motion to Dismiss 8 Complaint, and this Motion, I have expended well in excess of 212 hours of time. I 9 hereby proffer redacted timesheets for the months of September, October, November, 10 2013 detailing this time calculation. 11 12 I declare under penalty of perjury of the laws of the United States that the

13 foregoing is true and correct. 14 15 16 DATED: November 26, 2013 17 18 19 20 21 22 23 24 25 26 27 28 -4By: /s/

Colbern C. Stuart, III

Colbern C. Stuart, III, President, California Coalition for Families and Children, PBC, Lexevia, PC in Pro Se