Wednesday, July 22, 2009

SOPHIA STEWART OBJECTION AND RESPONSE

SOPHIA STEWART
P.O. BOX 31725
LAS VEGAS, NV 89173

IN PROPRIA PERSONA
IN THE UNITED STATES FEDERAL DISTRICT COURT
CENTRAL DISTRICT, STATE OF UTAH

SOPHIA STEWART,
Plaintiff,
v.
MICHAEL T. STOLLER, JONATHAN LUBELL, DEAN WEBB, GARY BROWN and JOHN DOES I through X, individuals whose identities are not yet known,

Defendants.
SOPHIA STEWART OBJECTION AND RESPONSE TO JONATHAN LUBELL, GARY BROWN, DEAN WEBB, AND MICHAEL STOLLER’S OBJECTION TO MOTIONS AND MEMORANDUMS FOR DEFAULT OF JUDGMENT AND MOTION TO STRIKE


Case No. 2:07cv00552
MAGISTRATE BRUCE C. WELLS


COMES NOW Plaintiff, Sophia Stewart (“Stewart”) bringing forth this “Objection and Response” To Defendants’ Jonathan Lubell, Dean Webb, Gary Brown, and Michael Stoller’s Opposition to Motions and Memorandums for Default of Judgment, and Objection for Motion To Strike Pleadings. The Defendants have committed “predicate acts’ of Fraud upon the court via mail and wire, while “Impugning” the “Integrity” of the Court.
The padded bills alone are sufficient to disbar all of the defendants, and the Court in examination of the “Perjury,” “Slanderous,” “Libel” statements, and Fraud, should issue an “Order” rendering “Default of Judgment,” and “Contempt of Court” for said Criminal Offenses and Intimidation of Stewart’s Civil and Constitutional Rights. It is “Gross Miscarriage of Justice” how said Defendants have been allowed to commit Perjury with impunity, while submitting Fraudulent, Slanderous and Libel Statements in utter “Contempt of the Federal Court System” as the Defendants’ “Willfully” violated Stewart’s Due Process, Equal Protection, and Rights to a Fair Trial availed by the her U.S. Constitutional and Civil Rights which have been trampled upon in this case. In addition, the Defendants being officers of the court have subverted the “Due Administration of Justice and Government Business,” due to discrimination based on “Gender and Race” because Stewart is an African American female compared to “Similar Situated” Jews and/or Whites as the Court System was utilized as an “Extortion Arena.” (Exh. T, Terminator DVD); (Exh. T2, Terminator II); (Exh. T3, Terminator (Exh. M, Matrix DVD); (Exh. M2, Matrix Reloaded,); (Exh. M3, The Matrix Revolution DVD); (Exh. M4, Matrix DVD)
Stoller, Brown, Webb, and Lubell received nearly $50,000.00 dollars from Stewart, and the Defendants “Willfully” in a “Premeditated Fraudulent Scheme” set-out to “Under Prepare” and “Ignore” the “Exculpatory Probative Evidence” on the “Issue of Guilt” against James Cameron, Gale Ann Hurd, Hemdale Films, Pacific Western Productions, Carolco Pictures, Larry Wachowski and Andy Wachowski; thus, said Defendants must be held accountable for violations of Fraud, Conspiracy to commit perjury upon the court, Civil and Constitutional violations of law pursuant to 18 U.S.C. 241 against Stewart as a member of the Minority Community. The Plaintiff asserts Lubell, Brown, Webb, and Stoller in a “Premeditated Diabolical Scheme” “Operated in Consort” to conceal from the U.S. District Court the establishment of “Access” to The Third Eye, six page movie treatment and the 45 page manuscript, as said Defendants intentionally “Cut Out” the “Operative Claims” and/or with “Malice” drafted an amended complaint intentionally “Riddled” with “Tortfeasor Errors” that specifically failed to state claims or liability against “Pacific Western Production” as the conduit of the “Constructive Trust.” The Defendants with “Malice” set out to “Under Prepare” and “Ignore” obvious facts and/or shelf “Probative Evidence” on the issue of guilt by concealing the actual six film DVDs to affirm “Access, Direct Copying Verbatim, and Substantial Similarity” to Stewart six page movie treatment, including but not limited to the 45 page manuscript of “The Third Eye.” Lubell was paid $1500 dollar to go to Washington to the U.S. Copyright Office and “Expedite the Fraudulent Copyrights filed by James Cameron, Gale Ann Hurd, Pacific Western Productions, Larry Wachowski and Andy Wachowksi and failed to carry out basic and/or any form of “legitimate” legal services as cited by the obvious fraudulent statements listed below with receipts. (Exhs. 130, 131, Contract by Bruce Isaac, dated 2007)
“J. Cameron “Assigned” to “Pacific Western Productions and Pacific Western Productions assigned to Hemdale Film…” (Exh. 11); (Exh. B, “The Third Eye, 45 Page Manuscript)
CONSPIRACY TO COMMIT “PERJURY” / PREMEDIATED FRAUDLENT SCHEME UPON THE COURT
Jonathan Lubell:
“Similarly, Affiant had no “Knowledge” or “Information” of “Pacific Western Article of Incorporation.” (Docket 72, pg. 5, Lubell Memorandum in Opposition Regarding the Motion For Judicial Notice); (Exhs. 135, 136, 137, 138, 139, 140, 141, Notice of Deposition of Cora Lee, dated March 25, 2005 and “Signed by Lubell, Stoller, Brown, and Webb); (Exh. A, Sophia Stewart Civil Complaint in the United State District Court of California, dated); (Exh. , Affidavit from Cora Lee with Jonathan Lubell’s name on the front)
“Affiant had no knowledge of or participation in any of the events or subjects referred to by Stewart in the paragraph.”( Docket 72, pg. 5)
“Affiant is the undeniable fact that Affiant had no “knowledge,” communications, agreements, negotiations, “Involvement” or “Any other relationship” with “Pacific Western Productions” or it’s representatives.” (Docket 72, pg. 7); (Exh. 11,12);
“Affiant was not involved in drafting any complaint against “Pacific Western Productions” or in considering the making of such claim. There is “no evidence” that Stewart “said anything about making such a claim” or the “failure to make such a claim.” More over, she produces not a scintilla of evidence that affiant and the three other lawyers were involved in a “Premeditated Fraudulent Scheme” when they drafted the Amended Complaint. (Docket 72, pg. 10); (Exh. A, Stewart’s Civil Complaint dated)
“Affiant has no knowledge or information regarding “Assignments” (“Emphasis Added”) or “Conspiracies” which Stewart puts in her Affidavit.” (Docket 72, pg. 11) ; (Exh. 11)
“Affiant has no knowledge of concealment from the Court of the February 15, 1994 copyright.” (Docket 72, pg. 15)
The first minute and 45 seconds of the first film produced by Pacific Western Productions, Inc. began with video dialogue that reads on her treatment, but appears nowhere in the screenplays of James Cameron from July of 1982 through February 3, 1984 when its written version was registered under Pau-584-564. The evidence that counters these representations was in the first minute and 45 seconds. The court sanctioned Petitioner for not putting forth evidence of infringement. Yet, the evidence was in the DVDs, the script, the draft, and the work product, in possession of Plaintiff’s Counsel and “obstructed and/or sitting” somewhere on the “Shelf” next to “Purchase Receipts." Neither James Cameron nor Hurd claimed authorship of that subject matter in the production.” (Exhs. 130, 131)
CONSPIRACY TO CONCEAL EVIDENCE / INTRINSIC FRAUD
“The liability of the directors of the corporation for monetary damages shall be eliminated.” (Exhs. 13, 14, 14.1, 14.3, 14.4, 14.5, Power of Attorney/Gagged Order/Concealment Judge Margaret M. Morrow/Fraudulent Concealment of Constructive Trust)
CONSPIRACY TO CONCEAL EVIDENCE / INTRINSIC FRAUD / PERJURY
“Affiant has “no knowledge of or participation” in any attempt to “conceal evidence” or “dupe” Judge Morrow. (Docket 72, pg. 6, Line K); (Exhs. 130, 131)
CONSPIRACY TO INTERFERE WITH GOVERNMENT DUTIES
“I have no ongoing inconsistent agreements with any other persons other than Phil Banks for this purpose. Phil Banks has agreed not to “Inform” (“Emphasis Added”) Judge Margaret Morrow of the “Subject Matter” (“Emphasis Added”) of his findings should the parties pay the amount previously offered which was authorized by me.” (Exhs. 14.6, 14.7, 14.8; Bruce Isaac Contract);
“CONSPIRACY” TO COMMITT PERJURY / MAJOR FRAUD
UPON THE COURT
Gary Brown:
“Brown denies that “Any Attorney” prevented Ms. Stewart from presenting her evidence and particularly denies that Brown committed malpractice.” (Docket. 39, Brown’s Answer to Complaint, Line 25, Sept. 23, 2008)
“Brown denies that he canceled Ms. Stewart's deposition and is not informed that “Anyone else Canceled” it and so must deny all of the allegation.” (Docket. , Line 46, Gary Brown Answer to Complaint dated July 30, 2007); (Exhs. 142, 143, Bruce Isaac dated March 24, 2005)
Jonathan Lubell:
“Affiant had not entered into any conspiracy with other attorneys for any purpose, including concealing information from Judge Morrow.” (Docket 72, pg. 5, Lubell Memorandum in Opposition Regarding the Motion For Judicial Notice) ; (Exhs. 130, 131)

PERJURY UPON THE COURT/ INTRINSIC FRAUD / INTERFERENCE WITH GOVERNMENT DUTIES
Gary Brown:
“I conferred with Jonathan Lubell. He is not able to be here for the deposition of Sophia Stewart on February 22, 2005, and is the “One” to prepare her. We suggest that the “discovery be postponed” until after the hearing on March 21, 2005” (Exhs. 29)
“With respect to your complaint that the attorneys failed to respond to the discovery requests, the attorneys stated that Messrs. Lubell, and Webb handled the discovery. Mr. Brown stated that he was “removed from your case on or about May 18, 2008, due to his health problems,” and that your complete file was turned over to Mr. Stoller. Mr. Stoller stated that, by the time he joined your case, prior counsel had already addressed the discovery matter.” (Exh. 50, 51, California Bar Association Letter, October 28, 2008); (Exh. 145, 146, 147, 148, 149, 150, 151, 152, 153, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, Declaration David H. Boren, dated March 28, 2005); (Exh. 170 Reporters Transcript); (Exhs. 175, 176, 177, P.O. Box 165153, Salt Lake City Utah 84116 Padded Bill dated “July 31, 2004”)

FRAUD / IMPEACHED TESTIMONY

“Ms. Stewart pretends to be a resident of Utah…. “That is where we “Always” contacted her. It was always my understanding that Ms. Stewart had immigrated from Utah to Nevada.” (Docket 73, Gary Brown Opposition, Pg. 5); ((Exhs. 175, 176, 177, P.O. Box 165153, Salt Lake City Utah 84116 Padded Bill dated “July 31, 2004”)


CONPSPIRACY TO COMMITT PERJURY UPON THE COURT

“On the road again, we are on the road again ...” (dated July 16, 2004, 11:14 PM Memo From Gary Brown to Jonathan Lubell); (Exhs. 180, 181, Letter from Lubell to Brown, dated “Feb. 22, 2005”)

In the process of Stoller blaming Webb and Brown, and Brown and Webb blaming Stoller, while Lubell erroneously denies “involvement” and/or “responsibilities of the other three, the Defendants have affectively affirmed “Intrinsic Fraud” by their efforts to have collected nearly $50,000 dollars and not performed “Any” legitimate legal service.”

INTRINSIC FRAUD UPON THE COURT IN VIOLATION
OF INDUSTRIAL ESPIONAGE ACT

“Affiant was not involved in the issue of whether the six films should have been lodged in the Court.” ((Docket 72, pg. 12)

W.B. Attorney David Boren:

“Therefore, both Lubell and Brown “Unilaterally” cancelled Ms. Stewart’s deposition one business day before it was scheduled to take place.” (Exhs. 145, 146, 147, 148, 149, 150, 151, 152, 153, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, Declaration David H. Boren, dated March 28, 2005)

“On Monday, February 21, 2005, (President Day), Bruce Isaacs received a call from an associate of Ms. Stewart, who stated that he was calling on behalf of Ms. Stewart. The associate (Lawyer) left a VOICEMAIL MESSAGE (“Emphasis Added) stating that Ms. Stewart was “unsure whether her deposition was going forward” and she was “unsure whether she should BOARD AN AIRPLANE (“Emphasis Added”) and FLY to Los Angeles to attend her DEPOSITION.” “The associate asked that Bruce call him to let him know whether Ms. Stewart should board and Airplane to fly to Los Angeles for her Deposition. This phone message showed that Ms. Stewart was “Indeed Available” to attend her deposition on February 22, 2005.” “Therefore, we were “Mystified” why Jonathan and Gary “Unilaterally Cancelled” Ms. Stewart’s “Deposition” when she was “Clearly Available” to be “Deposed.” (Exhs. Declaration of David H. Boren, pg. 7, dated March 28, 2005) (Exhs. 23, 24, 25, 26, 27, 28, Letter, March 18, 2005, pg. 3, lines 3-11); (Exh. 29, Gary Brown Dep. Cancellation, dated Feb. 18, 2005);

“Bruce and I called Stoller back at 4:30 PM to find out why we had not received the “Production of Documents” which were promised to be delivered that day, as well as, the other discovery responses.”

PREMEDIATED MAJOR FRAUD SCHEME / PERJURY / CONSPIRACY
AGAINST CIVIL &
CONSTITUTIONAL RIGHTS / 18 U.S.C. 241
Gary Brown:

“And I’m happy to also voice the fact, that “I haven’t seen” (“Emphasis Added”) the “Terminator” or “Matrix” movies. They are sitting on my “Shelf” (“Emphasis Added”) at home for me to “View.” (Exhs. 190, 191, Reporter’s Transcript Proceedings “Sept. 27, 2004”)

Jonathan Lubell:
“With reference to the actual movie source that was not submitted to the court, Affiant was “Never Involved” (“Emphasis Added”) with “that issue” (“Emphasis Added”) and “Never Discussed” with anyone at that time.” In fact, at the time that the movies would have been submitted, “Affiant no longer represented as a month before in “May of 1995,” she terminated his services.” (Docket 72, pgs. 10-11)

“Affiant has no relationship, knowledge or information regarding the alleged event. The response to the alleged concealment of evidence from Judge Morrow, is set forth is supra, II G.” (Docket 72, pg. 12)

“Affiant had not aided and abetted in the theft of the “Bereaved parties money.” (Docket 72, pg. 14)

“The Court has precluded Stewart from offering “testimony” in opposition to defendants’ motion for summary judgment. Thus, none of the evidence that she has submitted maybe considered.” (Exh. 194, Pg. 17, Lines 5-7, Judge Morrow, Court Order); (Exhs. 195, 196, Judge Morrow Crt. Order, Pg. 23, Lines 20 – 22); (Exh. 197, Judge Morrow Crt. Order, Pg. 32, Lines 22-23)
CONCLUSION
The Defendants’ Webb, Brown, Stoller, and Lubell, have not diligently defended their case for more than two years. In April of 2009, the Plaintiff filed her Default of Judgment, and to date said Defendants’ have “Unmercifully” committed Perjury upon the Court. For this reason, the Plaintiff is graciously requesting that the Court Issue an Order granting Default of Judgment.
I declare under the penalty of perjury that all of the foregoing are true and correct.
DATED: July 13, 2009 RESPECTFULLY SUBMITTED,


____________________________


CERTICATE OF MAILING
I hereby certify that on this __13____ day of July 2009, I caused to be mailed via first class U.S. mail, postage pre-paid, a true and correct copy of the foregoing S. Stewart Objection & Response + Memorandum in Support + Declaration in Support of Objection + Exhs. A, B, T, T2, T3, M, M2, M3, M4, 135, 136, 137, 138, 139, 140, 141, 145, 146, 147, 148, 149, 150, 151, 152, 153, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 175, 176, 177, 180, 181, 190, 191, 194, 197, 200, 209, 205, 206, 215, 216, 217, 218, 225230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243, to the following:


Jonathan Lubell
1325 6th Ave.
28th Floor
N.Y., New York 10019
212-763-8550

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Michael Stroller
Attorney at Law
9454 Wilshire Boulevard, Suite 500
Beverly Hills, California 90212


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Gary Brown
One Fair Oaks Avenue, Suite 301
Pasadena, California 91105


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Kathleen Liuzzi
DUNN & DUNN, PC
505 East 200 South 2nd Floor
Salt Lake City, Utah 84102

__X__U.S. Mail
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__X__Electronic Transmission
_____Hand-delivery
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c/o Court Clerk
United States District Court,
District of Utah.
350 South Main Street, Room 150,
Salt Lake City, UT 84101.
(1 Original & 2 Copies)

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I declare under the penalty of perjury under the laws of the State of Utah that the above is true and correct.
Respectfully Submitted,


Sophia Stewart

SOPHIA STEWART’S MEMORANDUM IN SUPPORT OF OBJECTION

SOPHIA STEWART
P.O. BOX 31725
LAS VEGAS, NV 89173

IN PROPRIA PERSONA
IN THE UNITED STATES FEDERAL DISTRICT COURT
CENTRAL DISTRICT, STATE OF UTAH

SOPHIA STEWART,
Plaintiff,
v.
MICHAEL T. STOLLER, JONATHAN LUBELL, DEAN WEBB, GARY BROWN and JOHN DOES I through X, individuals whose identities are not yet known,

Defendants.
SOPHIA STEWART’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF OBJECTION AND RESPONSE TO JONATHAN LUBELL, GARY BROWN, DEAN WEBB, AND MICHAEL STOLLER’S OBJECTION TO MOTIONS AND MEMORANDUMS FOR DEFAULT OF JUDGMENT AND MOTION TO STRIKE

Case No. 2:07cv00552
MAGISTRATE BRUCE C. WELLS

MEMORANDUM OF POINTS AND AUTHORITIES

“Because Stewart has not submitted copies of the Matrix films in opposition to the defendants motion for summary judgment, these comparisons can not be made.” (Exh. 198, Judge Morrow Court Order, pg. 49, lines 1-2); (Exhs. 230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243, Copyright Infringement /Comparisons by Jonathan Lubell Memo to Dean Webb, dated Oct. 12, 2004)

Brown, Webb, Stoller, and Lubell, “Fraudulently” Billed Stewart $284.50 dollars to acquire copies of the DVDs, CD, movies and musical soundtracks from local stores; in order, to submit said evidence into Court record. How can Brown, Webb, Stoller, and Lubell fraudulently collect nearly $50,000 dollars in legal fees, and expenses and thereafter “Admit” in a Federal Court to not have performed legitimate legal services? (Exh. T, Terminator DVD); (Exh. T2, Terminator II); (Exh. T3, Terminator (Exh. M, Matrix DVD); (Exh. M2, Matrix Reloaded,); (Exh. M3, The Matrix Revolution DVD); (Exh. B, “The Third Eye, 45 Page Manuscript); (Exh. 39, Padded Bill, “Best Buy, DVDs of Matrix Terminator “for Court filing of Mtn. to Reconsider, dated June 22, 2005”); (17 U.S.C. 106, 17 U.S.C. 501, 17 U.S.C. 506, and 18 U.S.C. 1001)

“By failing to proffer the alleged infringing films for the comparison with her work, and by failing to adduce any other admissible evidence of striking similarity she has failed to satisfy that burden.” (Exh. 198, Judge Margaret Morrow Court Order, Pg. 49, lines 5-7)

FRAUD / IMPEACHED TESTIMONY
Gary Brown:
“Further, she “Never Paid” me “Anything.” (“Emphasis Added”); (Docket 73, Gary Brown Opposition to Application For Default of Judgment and Request for Judicial Notice, pg. 2); (Exhs. 44.1, 44.2, Padded Bill Gary Brown)

“Our “Main Job” (“Emphasis Added”) now is “carefully assembling evidence” (“Emphasis Added”) and helping you prepare for a deposition.” (Exh. 225, Brown Memo, dated “October 30, 2004”)

“I don’t want us to become “Discredited” (“Emphasis Added”) by an “Unauthorized Move.” (Exh. 225)

FRAUD, FRAUD AND MORE FRAUD

“Thanks for sending money.” (“Emphasis Added”); (Exh. 225, Brown Memo, dated “October 30, 2004”)



“AFFRIMATION OF ACCESS”

“Whether the Matrix film was written “before” (“Emphasis Added”) or after October 26, 1993, has no relevance to the issues in the case, however, as Wachowski “Admits” (“Emphasis Added”) that the film was written in 1993, “after Stewart’s purported submission of the “Third Eye” to “Him,” and his brother in 1986.” (Exh. 198 , Judge Morrow Court Order, pg. 49, lines 25-27); (Caperton v. Massey, 08-22)

TERRORIST THREATS AGAINST LEGAL COUNSEL
18 U.S.C. 241 / RICO
Gary Brown:
“I also assure the Court that I have never “Intended” (“Emphasis Added”) to bother Mr. McBride about his representation of Ms. Stewart.” (Exh. 121)

SUBVERTING GOVERNMENT BUSINESS /ASCENTING IN CONSORT TO FRAUDULENT “EXTORTION LIENS” WITH CALCULATED FORETHOUGHT TO SCARE OFF ATTORNEYS

Jonathan Lubell:

“Affiant has not been involved in any activity which would have compromised or scared off attorneys.” (Docket 72, pg. 13); (Exhs. 21, 22, 63, 115, 116) (Uwe Geertz, Steven Fishman vs. Johnathan Lubell, Margaret M. Morrow, Judge, No. BC 122 468, dated 25 Dec 1995, Super. Crt., Cal., Cty., LA) - “Malicious Prosecution Complaint / Deprivation of Right to Counsel”)

PERJURY UPON THE COURT
CONSPIRACY TO COMMIT INTRINSIC FRAUD

Jonathan Lubell:
“Here is a draft of approximately half of our Initial Disclosure required under Rule 26(a), F.R.C.P. The full draft should be completed within 2 days! Your comments would be appreciated.”
“Gary, as we discussed, please send a letter to defendants' attorneys complaining about their “failure to “describe” the subjects of the information that their “witnesses” have.” (Exhs. 200, 201, Email Acknowledging Judy Neulak dated November 9, 2004)
INTRINSIC FRAUDULENT / PREPARATION OF FRAUDULENT DOCUMENTS TO JUDICIARY
“Finally, basic to Stewart’s claim against Affiant is the undeniable fact that Affiant had no “knowledge,” communications, agreements, negotiations, “involvement” or any “other relationship” with “Pacific Western Production” or its representatives. Whatever Stewart may imagine, Pacific Western Production was doing, Affiant was not involved.” (Exh. 11); ((Docket 72, pg )
How can it be justified that the Defendants Fraudulently Schemed to collect $50,000 dollars for legal services not performed from Stewart, and now has admitted to a Federal Court “No obligation” “knowledge” “communications,” and specifically “No Involvement” specifically with “Pacific Western Productions?” (Exh. 11); Buchwald v. Paramount Pictures, 1990 WL 357611 (Cal. Superior); (Dennis v. Sparks, 449 U.S. 24 (1980); (U.S. v. Cross, 128 F.3rd 148 (3rd Cir. 1997)); Caperton v. Massey, 08-22, The Ku Klux Klan Act of 1871)
INTRINSIC FRAUDULENT STATEMENTS / PERJURY STATEMENTS/IMPEACHED TESTIMONY
Response: “Affiant was not involved in drafting any complaint or claim against Pacific Western Production or in “Considering” the “Making” of any such claim. During the period when Affiant was attorney for Stewart, he never “Heard” or “Received” any “Statement, Comment, or Written Communication” from Stewart referring to making any claim against Pacific Western Production. There is no evidence that Stewart said anything about making such a claim or failure to make a claim. (Docket 72, pg. 10); (Exh. 11); (Exh. A, Stewart Civil Complaint)
The Defendants’ rendered Stewart equivalent to Dred Scott, in that she had no “Inalienable Rights” of “Ownership” in which a White man was bound to respect. The Defendants adopted President Andrew Johnson’s April 1866 “Black Codes” that obstructed her ability as an African-American from testifying against the Jewish members and gentile White men and women for “Theft” of Stewart’s Terminator and Matrix copyrights. Stewart in accordance with Judge Morrow asserts and affirms the Defendants Brown, Webb, Stoller, and Lubell having received nearly $50,000 dollars thereafter “Maliciously” drafted an “Inconsistent Complaint” that was designed to omit “significant” evidence on the issue of guilt against James Cameron, Gale Ann Hurd, and Pacific Western Productions, Larry Wachowski and Andy Wachowski thus amounting to “Intrinsic Fraud” and Constitutional and Civil Rights violations:
PREPARATION OF FRAUDULENT DOCUMENTS
“Stewart’s admissions conclusively establish that Cameron, Hurd, “Nor Any Other Person Connected with the Terminator” 1, 2, and 3 had access to the six page treatment or the 47 page Third Eye manuscript.” (Exh. 194, Judge Morrow Order, Pg. 17, Lines 15-16)
“Stewart is barred…. her admission that Fox had no role in creating, writing, and developing or producing Terminator 1, 2, and 3.” (Exh. Judge Morrow Order, pg. 19, lines 10-12)
MICHAEL T. STOLLER “UNSIGNED” DECLARATION JUNE 27, 2005 HIDDEN HILLS:

“I did not initially file an opposition to Defendants Motions For Summary Judgment on behalf of Plaintiff in light of the lack of discovery in the automatic admission conclusively established against her cause. After the court denied plaintiff’s motion for relief under the Fed.R.Civ.Pro. 60 (b), and granted Plaintiff three days, in which to file oppositions to the two motions for Summary Judgment, “I did not lodge the infringing films, as I believed that it was part of “Defendant’s Initial Burden” of establishing that there was no genuine issue as to independent creation and substantial similarity.” (Exh. 205, 206, Unsigned Declaration of Michael T. Stoller)

Objectively speaking, the fraud is staggering in this case, in terms of the scope of duration, and the “degree of betrayal,” as well as, "the breach of trust is massive." Jonathan Lubell, Dean Webb, Gary Brown, and Michael Stoller went far beyond the "garden variety of negligence" and crossed the line into willful misrepresentations amounting to grounds for Perjury, Contempt of Court, 18 USC §241 - Conspiracy against Civil Rights, and to Defraud by Interference with Government Functions, 18 USC §242 - Deprivation of Civil Rights under the color of law. The tone of “Detestation” by the Ivy league Harvard, New York University, Southwestern Univ., UCLA seasoned attorneys / “Scientologists” to proclaim the Utah Courts lacks “Authority” over their Fraudulent conduct reflects a “False” sense of “Privilege” to be above the law. Plaintiff objects to Brown’s Perjury Affidavit because it bares no “legitimate” signature. The Defendants crimes are "extraordinarily evil" and it was “not merely a bloodless crime” that takes place on paper but one that subverted “All” levels of Authority and Power of the Federal Branch of Government with utter “Disdain” and “Contempt” for U.S. Federal Court Justice System. (Exhs. 175, 176, 177, P.O. Box 165153, Salt Lake City Utah 84116 Padded Bill dated “July 31, 2004”); (Exhs. 110, 111, 113, 115 Idaho Bans Florida Foreclosure Rescue, Michael T. Stoller)
Plaintiff asserts Defendants Stoller, Brown, Webb, and Lubell breached their duties with fraudulent intent to fail to conduct discovery of any sort, failed in their legal duties to enter into court record the Terminator and Matrix six movies, including the federally protected intangible copyrights on the issue of guilt, failed in their legal duties to serve the Defendants with Interrogatories, misrepresented the true nature of judicial proceedings, “Prepared” and submitted “Fraudulent Admissions” on behalf of their client to a Federal Court System which resulted in “Baring/Gagging” her, while intentionally and willfully concealing the same, and providing false and misleading advice to their client in an attempt to convenience her not to amend her complaint in violation of 18 U.S.C. §24, and failed to file an “Appeal” on the Court matter. The defendants conduct was both “but for” and a proximate cause of an “egregious financial injury” to Stewart for the value of her copyrights for the Terminator and the Matrix in the amount of $7 billion dollar, plus $3.5 billion in “Punitive Damages” for a total value of $10.5 billion dollars. Based upon Defendants Stoller, Brown, Webb, and Lubell operating in consort to obstruct the 45 page manuscript from being entered into evidence, and the DVDs six movies of Terminator and Matrix from being entered into Court evidence, while said movies were actually sitting on the “Shelf” of Brown’ next to nearly $50,000 dollars worth of receipts, Plaintiff Stewart graciously requests the court grant her Default of Judgment.

I declare under penalty of perjury that all of the foregoing is true and correct.
Dated: July 13, 2009
Respectfully Submitted,


______________________________




















CERTICATE OF MAILING
I hereby certify that on this __13____ day of July 2009, I caused to be mailed via first class U.S. mail, postage pre-paid, a true and correct copy of the foregoing S. Stewart Objection & Response + Memorandum in Support + Declaration in Support of Objection + Exhs. A, B, T, T2, T3, M, M2, M3, M4, 135, 136, 137, 138, 139, 140, 141, 145, 146, 147, 148, 149, 150, 151, 152, 153, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 175, 176, 177, 180, 181, 190, 191, 194, 197, 200, 201 205, 206, 215, 216, 217, 218, 225 230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243, to the following:


Jonathan Lubell
1325 6th Ave.
28th Floor
N.Y., New York 10019
212-763-8550

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Michael Stroller
Attorney at Law
9454 Wilshire Boulevard, Suite 500
Beverly Hills, California 90212


__X__U.S. Mail
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__X__Electronic Transmission
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_____Other

Gary Brown
One Fair Oaks Avenue, Suite 301
Pasadena, California 91105


__X__U.S. Mail
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_____Electronic Transmission
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Kathleen Liuzzi
DUNN & DUNN, PC
505 East 200 South 2nd Floor
Salt Lake City, Utah 84102

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c/o Court Clerk
United States District Court,
District of Utah.
350 South Main Street, Room 150,
Salt Lake City, UT 84101.
(1 Original & 2 Copies)

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I declare under the penalty of perjury under the laws of the State of Utah that the above is true and correct.
Respectfully Submitted,


Sophia Stewart

AFFIDAVIT OF SOPHIA STEWART IN SUPPORT OF OBJECTION

SOPHIA STEWART
P.O. Box 31725
Las Vegas, NV 89173

IN PROPRIA PERSONA
IN THE UNITED STATES FEDERAL DISTRICT COURT
CENTRAL DISTRICT, STATE OF UTAH
SOPHIA STEWART,
Plaintiff,
v.
MICHAEL T. STOLLER, JONATHAN LUBELL, DEAN WEBB, GARY BROWN and JOHN DOES I through X, individuals whose identities are not yet known,

Defendants.

AFFIDAVIT OF SOPHIA STEWART IN SUPPORT OF OBJECTION AND RESPONSE TO JONATHAN LUBELL, GARY BROWN, DEAN WEBB, AND MICHAEL STOLLER’S OBJECTION TO MOTIONS AND MEMORANDUMS FOR DEFAULT OF JUDGMENT AND MOTION TO STRIKE

Case No. 2:07cv00552
Magistrate John C. Wells

Sophia Stewart declares:
1.I have personal knowledge of the matters set-forth in this Affidavit.
2.The Plaintiff asserts that Defendants’ Lubell, Webb, Brown, and Stoller “Maliciously” in a “Premeditated Diabolical Fraudulent Scheme” operated in “Consort” to “Prepare” and “Submitted” a plethora of “Fraudulent Admissions” on my behalf to the California Federal court without my knowledge and thereafter willfully conspired to conceal the same to circumvent my “Inalienable Rights Of Ownership,” thus constituting “Intrinsic Fraud.” Stoller, Brown, Lubell, and Webb, as well as, Judge Morrow are Church of Scientologist lawyers and should have disclosed their “Conflict of Interests,” “Withdrawn as Counsel,” including “Recusal;” however, said parties chose to secretly conceal this information, as Defendants trampled on my Civil and Constitutional Rights. I did not “Prepare” or “Submit” any of the Fraudulent “Admissions” listed below into the U.S. District Court of California, Case No.: CV-03-2873 MMM (VBXx):
“PREPARATION OF FALSE AND FRAUDULENT EVIDENCE TO JUDICIARY / JUDICIAL LYNCHING”
“Stewart’s admissions establishes that: (1) no person at Fox was involved in any way in creating , writing, developing or producing Terminator 1, 2, and 3; (2) Stewart has no factual basis or evidence to support the allegation that Fox provided Cameron a copy” of the treatment or the 47 – page manuscript; (3) Stewart “ha[s] no factual basis or evidence to support the allegations that Fox provided Hurd a copy” of the treatment or the 47 page manuscript; (4) Stewart “ha[s] no factual basis or evidence to support the contention that Fox provided any person connected with” Terminator 1, 2, and 3 a copy of the treatment or the 47 page manuscript; (5) Cameron did not have access to the treatment or 47 page manuscript; (6) and Hurd did not have access to the treatment or the 47 page manuscript. (Pg. 14, Lines 1 – 7)
CONSPIRACY TO PREPARE FALSE EVIDENCE TO DEFRAUD BY INTERFERENCE WITH GOVERNMENT FUNCTIONS
“The admission establish that: (1) no one at Warner Bros. had access to the six page movie treatment or 47 page manuscript prior to creation of Matrix 1; (2) Larry Wachowski and Andy Wachowski did not place an advertisement soliciting works of science fiction in a national magazine; (3) Stewart never submitted the treatment or 47 page manuscript to Larry Wachowski, Andy Wachowski, Silver or Bloom; (4) Larry Wachowski and Andy Wachowski, Silver and Bloom did not have access to the six page movie treatment or the 47 page manuscript prior to the creation of Matrix 1, 2, 3; and (5) Larry and Andy Wachowski independently created Matrix 1, 2, and 3. Stewart also admitted that no one connected with Matrix 1, 2, and 3 had access to the treatment or the 47 page manuscript.” (Pg. 24, Lines 13-19 & Pg. 48, Lines 1 – 2, Judge Morrow Court Order)
CONSPIRACY TO PREPARE FRAUDULENT /FALSE EVIDENCE TO JUDICIARY & JUDICIAL LYNCHING
“Stewart has admitted that Terminator 1is neither striking nor substantially similar to “The Third Eye” that Terminator 2, is neither striking nor similar to “The Third Eye,” and that Terminator 3 is striking nor similar to “The Third Eye. Stewart has also admitted that the protectable expression in “The Third Eye” is not substantially similar to the protectable expression in any of Terminator 1, 2, and 3.” (Pg. 41, Lines 1 – 9, Judge Morrow Court Order)
“Stewart’s admission that the 47 page manuscript is not substantially similar or strikingly similar necessarily encompasses any similarities found in the synopsis .” (Pg. 42, lines 6-7, Judge Morrow Order); (Exh. T, Terminator DVD); (Exh. T2, Terminator II); (Exh. T3, Terminator (Exh. M, Matrix DVD); (Exh. M2, Matrix Reloaded,) (Exh. M3, The Matrix Revolution DVD); (Exh. Total Recall DVD)
“Stewart has also admitted that the protected expression in “The Third Eye” is not substantially similar to the protected expression in any of Terminator 1, 2, and 3. (Exhs. Pg. 41, lines 8 – 9, Order Dismissing Case.)
“Stewart admission that the 47 page manuscript is not substantially or strikingly similar necessarily encompassing any similarities found in the synopsis. Here admissions, therefore, establish that there are no striking similarities between the works. (Exh. Pg. 42, lines 5-8, Order Dismissing Case)
3.Attorney General of Florida brought forth “Indictments” against Michael T. Stoller who is the Owner of Mortgage Assistance Solutions llc, case no. L06-3-1014. [See: Los Angeles Bar Association Complaint number former “Government Federal Post Office worker” - Keith & Danielle Hardesty, 08014737 dated April 13, 2009 – Caused the Homelessness of a “Government Federal Post Office Worker” and his family with 8 children that are now all dispersed and living in a car in Pasadena and across different homes throughout the U.S..]; (http://www.mortgagefraudblog.com/index.php/weblog/permalink/idaho_bans_florida_foreclosure_rescue/);(Colannino v County of L.A., BC413089); (Exhs. 110, 111, Idaho Bans Florida Foreclosure Rescue, Michael T. Stoller) (Exhs. 114, 115) Enclosed herewith, you shall find further misconduct by Dean Browning Webb for a rambling lawsuit. (Exh. 116) Michael Stoller had 72 counts of Mortgage fraud, $2 million dollars in penalties and fees, and he is banned from practicing law in Texas, Florida, and Illinois. The attorney general of Illinoise Lisa Madigan brought indictments against Stoller.
The Conversion of “The Third Eye” into the “The Terminator”
4.I wrote a treatment for a motion picture regarding a post nuclear war fight between man and machine conscious organisms without feelings or empathy and completed it on May 1, 1981. Upon completion of the treatment, I sent the document to the Vice President of Creative Affairs of Twentieth Century Fox, Susan Merzbach before May 6, 1981. On May 12, 1981, just days after it was submitted, Corman’s public relations and marketing assistant, Gale Ann Hurd, a graduate of Stanford University, started Pacific Western Productions, Inc. in California.
5.The only story that was worked on by Pacific Western Productions from May of 1981 through October of 1984 had to do with a post nuclear war fight between man and machines appearing to be as men called cyborgs. Through Fox, New World Productions had access. Through New World Productions, Pacific Western Productions, Inc. had access to my treatment called the “Third Eye”.
6.By virtue of “Access,” the aspect of The Terminator and Matrix that are substantially similar to my copy written work of The Third Eye is the first minute and 45 seconds of the first film produced by Pacific Western Productions, Inc. It began with video dialogue that reads on my screen treatment, The Third Eye, but appears nowhere in the screenplays of James Cameron from July of 1982 through February 3, 1984 when its written version was registered under Pau-584-564.
7.This significant evidence in the screenplay is extraordinarily significant since that it is the first section of film footage produced by Pacific Western Productions.
The police officer answered Kyle Reese
"What day is it?"
“May 12th."
8.It is the day when the Terminator sought to take out Sarah Connor in the film. It is the actual day when Gale Anne Hurd set out to take out all of my intellectual property rights so that their production group would not experience the theater prejudice that had been previously experienced by Roger Corman of New World Productions, Inc. when he made "The Intruder", a film about racial desegregation in the sixties.
9.Racial discrimination by concerted action is a federal offense under 18 U.S.C. 241. The failure to disclose a true Author on a copyright registration is a violation of 17 U.S.C. 201, 18 U.S.C. 1001, and 17 U.S.C. 506. The combination and conspiracy against trade by prior anyone is a federal “Antitrust crime” under 15 U.S.C. 1. You can not overcome a criminal act by taking the copyright of an African American and then trying to impose the Dred Scott decision on me as if I was a pre-civl war slave who had no rights that a White was bound to respect. Dred Scott v. Sanford has been a nullity in the United States at least since the 1868 adoption of the Fourteenth Amendment that gave such persons citizenship. The willful deprivation of my copyright rights is an offense under 18 U.S.C. 241 and 18 U.S.C. 1001.
10.When my work was commercially sold without recognizing my authorship or entitlement to share in the revenue, James Cameron, Gale Ann Hurd, and Hemdale Films, Pacific Western Productions, Carolco Pictures, Mario F. Kassar, Andrew G. Vajna, Andy Wachowski, Larry Wachowski, and Fox, Inc. knowingly and willfully engaged in copyright infringement within the meaning of 17 U.S.C. 506. The first minute and 45 seconds of the film entitled the "Terminator" actually comes from my May 1, 1981, copy written treatment that was sent to Fox between May 1, 1981 and May 7, 1981. Gale Hurd through Roger Corman of New World Productions, Inc. commenced her company on May 12, 1981 to terminate my intellectual property rights. Substantial similarity is supported under 17 U.S.C. 106, 17 U.S.C. 501, 17 U.S.C. 506, and 18 U.S.C. 1001.
Access and Substantial Similarity Automatically Support a Finding of Infringement
11.In Dezendorf v. Twentieth Century Fox, the court held that the theft of an unpublished work that is then placed in a final commercial work of another without the consent of the prior author is evidence of infringement.
12.The authorship for the registration dated February 3, 1984 under the names of James Cameron and Gale Hurd is a false statement in that they willfully failed to disclose my contribution being the sole author of “The Third Eye,” of which, makes me the only “Author” of “The Terminator” and the “Matrix” movies and sole Owner of the Copyrights.
13.Yes, it is true that neither James Cameron nor Gale Anne Hurd represented in the screenplay registered with the Writer’s Guild in July of 1982 or the final draft submitted to the copyright office in February of 1984 that they authored the language that describes the visual dialogue shown in the first minute and 45 seconds. This visual dialogue shown in the first 1 minute and 45 seconds is hidden in plain sight. If you do not compare the movies with my work, then you would have missed this significant issue. This primary issue would have won me the California judgment. This is the reason why the Defendants operated in consort to obstruct the six films of the “Terminator,” “Matrix,” and six page movie treatment “The Third Eye” from being entered into court evidence. This description is evidence of the intent of the parties to engage in willful copyright infringement within the meaning of 17 U.S.C. 506 (e).
EXT. School yard – Night 2
14.Frame comes to rest on the figure of a naked man kneeling, faced away, in the previously empty yard. He stands slowly. This man is in his late thirties, tall and powerfully built, moving with graceful precision. The first minute and 45 seconds of the film includes visual dialogue that is not written into the first, second, third, fourth, or fifth draft of the screenplay. Actual depiction of the introduction of the Terminator Film does not include the cat, the war scene, or the statement overlay.
15.On April 29, 2005, Motion for Summary Judgment submitted to the Court by Bruce Isaacs, Legal Counsel of the Defendants in the California Court, Case No. CV-03-2873 MMM (VBKx), he did not disclose to the court, nor did Lubell, Webb, Brown, and Stoller disclose the following facts:
1) that the first minute and 45 seconds of the film does not read on the screenplay by Cameron and Hurd;
2) that the first minute and 45 seconds of the film does read on the treatment by Sophia Stewart dated May 1, 1981;
3) that the May 1, 1981 treatment was sent to Fox before May 7, 1981;
4) that the May 1, 1981 treatment was transferred from Fox to Roger Corman of New World Pictures prior to May 9, 1981;
5) that Gale Hurd, Corman's assistant, started Pacific Western Productions on May 12, 1981 while James Cameron was in Italy and did not know about the May 1, 1981 treatment;
6) Cameron was required to play along with Hurd to get the opportunity to write and direct the project based upon Stewart's work product.
7) that the first minute and 45 seconds of the Terminator and Matrix movie introductions reads verbatim upon my treatment The Third Eye, including the characters are conclusive with investigative findings of the FBI.
15. The Defendants knowingly and willfully failed in their legal responsibilities to timely file “Default of Judgment” against Andy and Larry Wachowski, because the Wachowskis never responded to the Summons, and the First Amended Complaint. (Exhs. 215, 216)

16. Dean Webb “Sexually Harassed” me with numerous phone calls. Webb contacted me at “Wee-Hours” of the night inappropriately using explicit “Sexual language.” Right after Judge Morrow’s ruling of the dismissal of the RICO claims without prejudice with leave to amend, Dean Webb immediately abandoned the case after he sabotaged it, and I did not receive any more phone calls:
Dean Webb:
“Here is my picture, taken around 4:00 p.m., this afternoon by my brother Rob=rt. I told you I needed my hair cut, and I “Wetted down my hair” (“Emphasis Added”) and “Pulled off my Glasses!” “Hope your not disappointed.” (“Emphasis Added”) “Next time I'll wear a suit and tie!” (“Emphasis Added”); (Exhs. 217, 218)
17. In light of “Demeaning and Derogatory” comments by Dean Webb, Michael Stoller, Gary Brown, and Jonathan Lubell it would be a “Gross Miscarriage of Justice” for the Court to allow the Defendants to further “Impugn the Integrity of the Court” through willful acts of “Perjury,” “Slander, “Libel,” and “Retaliation.” These are the reasons why, I should be granted Default of Judgment.
PRAYER FOR JUDGMENT
18. WHEREFORE, Plaintiff prays for judgment against Defendants, and each and everyone of them, jointly and severally as follows:
1)Compensatory Damages
2)Recovery of Reasonable Attorney Fees and Costs arising
3)Punitive Damages
4)For such further and other relief as the court deems just and proper
I declare under the penalty of perjury that all of the forgoing is true and correct to the best of my knowledge and belief.









DATED this__13___ day of July, 2009

Submitted,



_____________________________ SOPHIA STEWART


STATE OF _____________ )
):ss
COUNTY OF ___________ )

On the _______ day of Affidavit, July 2009, personally appeared before me Sophia Stewart, the signer of the foregoing Affidavit, who duly acknowledged that he executed the same.
_____________________________
Notary Public
My Commission Expires: _________


CERTICATE OF MAILING
I hereby certify that on this __13____ day of July 2009, I caused to be mailed via first class U.S. mail, postage pre-paid, a true and correct copy of the foregoing S. Stewart Objection & Response + Memorandum in Support + Declaration in Support of Objection + Exhs. A, B, T, T2, T3, M, M2, M3, M4, 135, 136, 137, 138, 139, 140, 141, 145, 146, 147, 148, 149, 150, 151, 152, 153, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 175, 176, 177, 180, 181, 190, 191, 194, 197, 200, 201 , 205, 206, 215, 216, 217, 218, 225, 230, 231, 232, 233, 234, 235, 236, 237, 238, 239, 240, 241, 242, 243 to the following:

Jonathan Lubell
1325 6th Ave.
28th Floor
N.Y., New York 10019
212-763-8550

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Michael Stroller
Attorney at Law
9454 Wilshire Boulevard, Suite 500
Beverly Hills, California 90212


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Gary Brown
One Fair Oaks Avenue, Suite 301
Pasadena, California 91105


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Kathleen Liuzzi
DUNN & DUNN, PC
505 East 200 South 2nd Floor
Salt Lake City, Utah 84102

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c/o Court Clerk
United States District Court,
District of Utah.
350 South Main Street, Room 150,
Salt Lake City, UT 84101.
(1 Original & 2 Copies)

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I declare under the penalty of perjury under the laws of the State of Utah that the above is true and correct.
Respectfully Submitted,



Sophia Stewart