PLNTFS MTN RE RULE 11 SANCITONS

Case No. 13-cv-1944-CAB (BLM)

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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, PBC. and
Lexevia, PC


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

CALIFORNIA COALITION FOR
FAMILIES AND CHILDREN, et al.,

Plaintiffs,

v.

SAN DIEGO COUNTY BAR
ASSOCIATION, et al.,

Defendants
Case No. 13-cv-1944-CAB (BLM)
J udge: Hon. Cathy Ann Bencivengo
NOTICE OF MOTION FOR
SANCTIONS; F.R.C.P. 11(b)

Date: J anuary 24, 2014
Time: 2:00 p.m.
Courtroom: 4C

ORAL ARGUMENT REQUESTED
SUBJ ECT TO COURT APPROVAL


Complaint Filed: August 20, 2013


PLEASE TAKE NOTICE that on J anuary 24, 2014, at 2:00 p.m., or as soon
thereafter as the matter may be heard in the above-entitled Court, located at 221 West
Broadway, San Diego, California, Plaintiff COLBERN C. STUART will move the
Court pursuant to Federal Rule of Civil Procedure 11(b)1-3 and Local Rule 83.1
against SUPERIOR COURT SUPERIOR COURT DEFENDANTS on the grounds
that the MTD:


PLNTFS MTN RE RULE 11 SANCITONS
Case No. 13-cv-1944-CAB (BLM)
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(1) is being presented for improper purposes including to continue a pattern of
retaliation, HARASSMENT and ABUSE, and CHILLING described more fully in
the Complaint and the August 26, 2013 Ex Parte Application and Motion for a
Harassment Protective Order. Dkt #4;
(2) contains claims which are not warranted by existing law or by a
nonfrivolous argument for extending, modifying, or reversing existing law or for
establishing new law; and
(3) contains a request for judicial notice and other factual contentions with no
evidentiary support in violation of Rule 11(b)(l)-(3).
This Motion will be based on this Notice of Motion and Motion, the
Memorandum of Points and Authorities and Declaration of Colbern Stuart in support
hereof, Plaintiffs (1) Ex Parte Application of Harassment Restraining Order (Dkt#4),
(2) Motion to Strike Matter In Support of Defendants Motion to Dismiss (Dkt#19),
(3) Opposition to Defendants Motion to Dismiss Complaint (Dkt#21), and (4) the
Declaration of Colbern C. Stuart in Support of Motion to Strike/Opposition to Motion
to Dismiss Complaint (Dkt#21-1), and all pleadings and papers on file with this
Court.



DATED: November 26, 2013 By: /s/

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



Colbern C. Stuart, III


PLNTFS MTN RE RULE 11 SANCITONS
Case No. 13-cv-1944-CAB (BLM)
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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
26
th
day of November, 2013.


By: /s/

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


Colbern C. Stuart, III