Albert L. Peia, ProSe
P.O. Box 370434
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Albert L. Peia, ) Case No. CV 02-4507-DDP(RNBx)
) PLAINTIFF’S DECLARATION/CERTI-
Bernal P. Ojeda, )FICATION IN SUPPORT OF MOTION
Rene Lopez DeArenosa, ) FOR SUMMARY JUDGMENT AGAINST
and John Does 1 – 15, ) DEARENOSA.
I, Albert L. Peia, hereby certifyand declare under
1. I am the pro seplaintiff in the present matter and if called upon to testify I could and wouldcompetently testify (truthfully) to the following facts of my own personalknowledge.
2. The complaintin the instant matter is a verified complaint, the averments of which are setforth under penalty of perjury.
3. The exhibitsset forth in the instant summary judgment motion are also contained in saidverified complaint and incorporated therein by reference thereto.
4. In a furtheraffront to and mockery of the legal process, defendant De Arenosa hasinterposed a (bad faith) general denial to the averments of said verifiedcomplaint herein.
5. DeArenosa’s partner in crime, Ojeda, (both purportedly“lawyers” who should be disbarred) is once again attempting toavoid being served with process. Exhibit “1a” (the process manager atPersonal Attorney Service indicated that upon calling Ojeda’s new office,they were refused the address of same by employee(s) thereof).
6. Alsoincorporated by reference as Exhibit “E3” to the verified complaintand Exhibit “1b” herein is the perjurious declaration of defendantDe Arenosa dated 6-8-01 in which he declares “under penalty of perjuryunder the laws of the State of California” that he did not receive therequest for the entry of default /default judgment.
7. Alsoincorporated by reference as Exhibit “E2” to the verified complaintand Exhibit “2a” herein is the letter by defendant De Arenosa dated2-21-01 indicating that contrary to his perjuriously false declaration he hadindeed received the request to enter default/default judgment (parenthetically,it is probable that De Arenosa had every reason to believe that this letter,which I had kept separate from the file in the original envelope and hidden,was among the evidentiary items illegally taken from the file, ie., pictures,etc., and had to “dig out” from ultimately, my storage unit).
8. Incorporated byreference as Exhibit “E4” to the verified complaint and Exhibit“2b” herein is evidence of defendants use of the U.S. mail toperpetrate their crime(RICO) and fraud.
9. Incorporated byreference as Exhibit “E5” to the verified complaint and Exhibit“3” (3a & 3b) herein are damages to plaintiff’s propertyand business as a direct and intended consequence of defendant DeArenosa’s crime (RICO), perjury, and fraud.
10. I declare underpenalty of perjury pursuant to the laws of the state of California and theUnited States of America that the foregoing is true and correct.
Dated: 8-02-02 Signed: _________________________
Albert L. Peia, Pro Se