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Colbern C. Stuart III
Email: Cole.Stuart@Lexevia.com
4891 Pacific Highway Ste. 102
San Diego, CA 92110
Telephone: 858-504-0171
Facsimile: 619-231-9143
In Pro Se

Dean Browning Webb (pro hac vice pending)
Email: ricoman1968@aol.com
Law Offices of Dean Browning Webb
515 E 39th St.
Vancouver, WA 98663-2240
Telephone: 503-629-2176

Attorney for Plaintiffs California Coalition for Families and Children, Inc. and
Lexevia, PC


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

CALIFORNIA COALITION FOR
FAMILIES AND CHILDREN, et al.

Plaintiffs,

vs.

SAN DIEGO COUNTY BAR
ASSOCIATION, a California
Corporation, et al,

Defendants.
Case No. 13cv1944-CAB-BLM
J udge Cathy Ann Bencivengo


DECLARATION OF COLBERN C.
STUART IN SUPPORT OF MOTION TO
STRIKE/OPPOSIITON TO MOTION TO
DISMISS COMPLAINT

Date: November 22, 2013
Time: 3:30 p.m.
Courtroom:4C

ORAL ARGUMENT REQUESTED
SUBJ ECT TO COURT APPROVAL


Complaint Filed August 20, 2013







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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 Lexevia, PC. I have personal
knowledge of the facts stated herein and if called to testify would competently testify
as follows:
1. On September 30, 2013, I was served with Defendants Motion to Dismiss
Complaint, Request for J udicial Notice, Declaration of Kristine Nesthus, and Exhibits
thereto.
2. I have reviewed the Motion and conducted research in response to the issues
raised therein. My research indicated that the Motion to Dismiss is brought on
numerous irrelevant, inappropriate, and inadmissible grounds, arguments, and
evidence.
3. In order to address the motions breadth and misguided direction, I prepared
a detailed letter in an attempt to initiate meet and confer negotiations with Defendants
(M&C). A true and correct copy of my letter is attached hereto as Exhibit A.
4. Two days letter, on September 30, 2013, I received correspondence from
Defendants attached hereto as Exhibit B declining to engage in meet and confer
discussions, declining to stipulate to withdraw and/or amend pleadings informally, an
declining to stipulate to a mutual briefing page limit extension.
5. As Plaintiff in pro se and President and Chief Executive Officer of both
corporate co-plaintiffs, I have personal knowledge of all facts alleged in the
Opposition to Defendants Motion to Dismiss Complaint, including those facts
relating to each Plaintiffs ability to plead additional matter in an amended pleading.
If granted leave, I and my corporate co-plaintiffs can and will plead additional facts
and details as indicated in the Opposition.



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I declare under penalty of perjury of the laws of the United States that the
foregoing is true and correct.

Respectfully Submitted



DATED: November 8, 2013 By: /s/

Colbern C. Stuart, III, President,
California Coalition for Families and
Children
in 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
8
th
day of November, 2013.


By: /s/

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

Colbern C. Stuart, III