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

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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