Albert L. Peia, Pro Se

P.O. Box 370434

Reseda, CA 91337-0434

 

 

                  UNITED STATES DISTRICT COURT

                 CENTRAL DISTRICT OF CALIFORNIA

 

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                          )

  Albert L. Peia,         ) Case No. CV 02-4507-DDP(RNBx)

                Plaintiff )

                          )

            -vs-          )

                          ) 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.

               Defendants )

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   I, Albert L. Peia, hereby certify and declare under

 

penalty as follows:  

 

1.    I am the pro se plaintiff in the present matter and if called upon to testify I could and would competently testify (truthfully) to the following facts of my own personal knowledge.

2.    The complaint in the instant matter is a verified complaint, the averments of which are set forth under penalty of perjury.

3.    The exhibits set forth in the instant summary judgment motion are also contained in said verified complaint and incorporated therein by reference thereto.

4.    In a further affront to and mockery of the legal process, defendant De Arenosa has interposed a (bad faith) general denial to the averments of said verified complaint herein.

5.    De Arenosa’s partner in crime, Ojeda, (both purportedly “lawyers” who should be disbarred) is once again attempting to avoid being served with process. Exhibit “1a” (the process manager at Personal Attorney Service indicated that upon calling Ojeda’s new office, they were refused the address of same by employee(s) thereof).

 

 

6.    Also incorporated by reference as Exhibit “E3” to the verified complaint and Exhibit “1b” herein is the perjurious declaration of defendant De Arenosa dated 6-8-01 in which he declares “under penalty of perjury under the laws of the State of California” that he did not receive the request for the entry of default /default judgment.

 

7.    Also incorporated by reference as Exhibit “E2” to the verified complaint and Exhibit “2a” herein is the letter by defendant De Arenosa dated 2-21-01 indicating that contrary to his perjuriously false declaration he had indeed 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 by reference as Exhibit “E4” to the verified complaint and Exhibit “2b” herein is evidence of defendants use of the U.S. mail to perpetrate their crime(RICO) and fraud.

 

9.    Incorporated by reference as Exhibit “E5” to the verified complaint and Exhibit “3” (3a & 3b) herein are damages to plaintiff’s property and business as a direct and intended consequence of defendant De Arenosa’s crime (RICO), perjury, and fraud. 

 

 

10.    I declare under penalty of perjury pursuant to the laws of the state of California and the United States of America that the foregoing is true and correct.

 

Dated: 8-02-02            Signed: _________________________

                                   Albert L. Peia, Pro Se