IN THE UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PAUL SHAFER AND JOSHUA HARDER. Plaintiffs, v.

RODERICK BREMBY, Defendants. ) ) ) JUDGE THOMPSON ) ) CASE NO. 3:12-CV-00039-AWT

MEMORANDUM OF LAW IN SUPPORT OF MOTION OF BETTY J. KING FOR RULE 11 SANCTIONS AGAINST DEFENDANT BREMBY AND COUNSEL May it please the Court: The application for Betty King was COMPLETE on 15 December 2011 yet Defendants failed to take action until Intervenor sued them in September of 2012. Here is a summary of emails for the Courts edification. This response is a sworn response, noting that Diane Wood told Intervenor to keep sending these emails regarding the delay so that they could document the problem. **************** On January 23, 2012: Betty King info. Hi Diane, I know I am blowing up your email, sorry. I also know you've got about a billion other things on your plate as well. Thanks, ***************** On January 18, 2012: Any word yet on Betty King app? Thanks, Diane. On 16 Dec. 212 Diane Wood sent a confirmatory email regarding the last document, i.e. the Divorce Decree:

The package will expire on Sunday January 15, 2012 at 08:22:55 EST5. *************** On 15 December Intervenor provided the last necessary document -- the divorce decree:

*************** On 14 Nov. 2011 Intervenor wrote: Betty King updates -- final docs for Title XIX 1. Foreclosure: I found the Sheriff sale proof online and it is attached. Please confirm you can open and read it. 2. U.S. Bank: The package was sent and is at my apartment awaiting my return on Wed night or TH morning -- I will overnight to you. 3. Divorce Decree My father is going to fax to me shortly and I will scan and send in the next 48 hours. 4. W-1SA: Calling you now I need to find this document and send it to you. Will call you again to find it. That should complete everything. Again Diane thank you for your help. Sincerely,

********** On 22. Nov. Intervenor wrote: The Application. Note this email contained the W-1.

That is why on 20 Jan, 2012 Intervenor wrote Diane Wood: Hi Diane, I was just looking at the submission.... is there anything more that we could do. I'm stressing. Thanks and have a great weekend. Intervenor's sister a very established corporate executive with no propensity to lie -wrote on the same day: Thanks Chris, good follow up. We are both concerned about the process and outcome. Thanks for your attention to this matter. ********** 27 August: Hello Ms. Wood, We are all concerned about our mother and this process. Do you have any more news or information for us? Thank you in advance. Sincerely, Again from Intervenor's sister: Thanks for the note Chris. Ms Wood as Chris stated we are concerned and I do not understand why this had not been resolved. We would like a full accounting of the procedures and the plans to get this approved or what has to be done to escalate it. At this stage we can no longer continue waiting.

As such, Defendant's first Defense is clearly without merit and this Court must issue a stern rebuke to Defendants via the immediate imposition of sanctions, as all they needed to do (and what they were obligated to do) per Rule 11 was to read their own emails. Plaintiff will mail a conventional, signed and notarized copy to the Court for filing later today, 17 December 2012. /s/ Christopher King, J.D. _____________________________ Christopher King, J.D. http://KingCast.net -- Reel News for Real People kingjurisdoctor@gmail.com 617.543.8085 _____________________ NOTARY PUBLIC MY COMMISSION EXPIRES: ______________ CERTIFICATE OF SERVICE I the undersigned, solemnly swear that a true copy of this Memorandum Was delivered via email on 23 November 2012 And via Regular U.S. Mail, 23 September 2012 to: Defendant Roderick Bremby c/o Jennifer L. Callahan, Esq. ct 29033 CT AG 55 Elm Street PO Box 120 Hartford, CT 06141 hugh.barger@ct.gov Plaintiffs Shafer and Harder Sheldon Toubman (ct08533) New Haven Legal Assistance Assoc. 426 State Street New Haven, CT 06510-2018 Phone: 203.946.4811 Fax: 203.498-9271 stoubman@nhlegal.org /s/Christopher King, J.D. __________________________________ KingCast.net By and through Christopher King, J.D. 617.543.8085m