1 Paul Andrew Mitchell, Sui Juris 2 c/o UPS PMB #332 3 501 W. Broadway, Suite “A” 4 San Diego 92101 5 CALIFORNIA, USA 6 7 tel: (619) 234-5252 (messages) 8 fax: (619) 234-5272 9 10 In Propria Persona 11 12 All Rights Reserved 13 without Prejudice 14 15 16 Superior Court of California 17 18 San Diego County 19 20 21 Paul Andrew Mitchell, ) Case No. GIC807057 22 ) 23 Plaintiff, ) PLAINTIFF’S REPLY TO ANSWER 24 v. ) OF DEFENDANT MSEN, INC.: 25 ) 26 AOL Time Warner, Inc., et al., ) 18 U.S.C. 1964; 27 ) CCC 22.2 28 Defendants. ) (common law is rule of decision). 29 ) 30 ______)

31 COMES NOW Paul Andrew Mitchell, Plaintiff in the above entitled case,

32 Citizen of California, Private Attorney General and Federal Witness,

33 to file his REPLY TO ANSWER OF DEFENDANT MSEN, INC. (“MSEN”).

34 Plaintiff begins with generic rebuttals, then follows with

35 specific rebuttals to each affirmative defense as stated in MSEN’s

36 untimely answer.

37 1. There is no evidence on record that Mr. Lawrence F. Meyer is

38 properly licensed to practice law in California courts. A State Bar

39 Number (“SB”) is not a license to practice law. A certificate of oath

40 must be indorsed upon all licenses to practice law. See § 6067 of the

41 California Business and Professions Code (“CBPC”). Also, Bar cards

42 make no mention whatsoever of any State or federal constitutions.

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 1 of 30 1 On July 10, 2003 A.D., Plaintiff lawfully demanded that Mr. Meyer

2 exhibit a proper certificate of oath no later than 5:00 p.m. on

3 Monday, July 21, 2003 A.D. See Attachment “A”. To date, Plaintiff

4 has received no reply to that demand from Mr. Meyer. Plaintiff

5 expressly reserves his Right to move this court for an order striking

6 MSEN’s answer entirely, for having been filed by an unlicensed

7 representative without any lawful powers of attorney to do so.

8 2. The date of MSEN’s answer -- July 7, 2003 -- is far beyond the

9 deadline for answers as stated on the original SUMMONS issued in this

10 case. That SUMMONS clearly stated that MSEN had “30 CALENDAR DAYS”

11 after the SUMMONS was served to file a typewritten response at this

12 court. The SUMMONS and Initial COMPLAINT were mailed via Certified

13 U.S. Mail from downtown San Diego on April 17, 2003 A.D. The United

14 States Postal Service PS Form 3811 return receipt (“green card”) was

15 postmarked April 23, 2003 A.D. See Attachment “B”.

16 3. Plaintiff is entitled to the requested relief, and to all other

17 relief which this honorable Court deems just and proper.

18 4. In further reply to MSEN’s untimely answer, Plaintiff now

19 incorporates the following additional Attachments by reference, as if

20 set forth fully here:

21 “C” Network Solutions WHOIS database entry for domain MSEN.COM 22 www.supremelaw.org/copyrite/msen.com/NSI - WHOIS Search Results.htm 23 24 “D” DEMAND FOR AUTHORIZATION, July 13, 1998 A.D. (Exhibit K-30) 25 www.supremelaw.org/copyrite/msen.com/showletter.htm 26 27 “E” “The Federal Zone” Copyright Amnesty Program, as mailed on 28 June 27, 1999 A.D. to CEO, Msen, Inc., Troy, Michigan, e.g.: 29 www.supremelaw.org/letters/amnesty.htm 30 31 “F” U.S. Copyright Office, Directory of Service Provider Agents for 32 Notification of Claims of Infringement (no entry for MSEN) 33 www.supremelaw.org/copyrite/msen.com/usloc.m-agents.htm

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 2 of 30 1 “G” referral to related folders in database of evidence 2 www.supremelaw.org/copyrite/msen.com/referral.htm 3 4 “H” MIRANDA WARNING, to CEO, Msen, Inc., Feb. 18, 2001 A.D. 5 www.supremelaw.org/copyrite/msen.com/miranda.htm 6 7 “I” NOTICE OF INTENT TO SUE, to CEO, Msen, Inc., Feb. 18, 2001 A.D. 8 www.supremelaw.org/copyrite/msen.com/intentsue.htm 9 10 “J” DEMAND FOR SUBSCRIBER IDENTITY, to CEO, Msen, Inc., May 7, 2001 11 www.supremelaw.org/copyrite/msen.com/subid.htm 12 13 “K” NOTICE OF DEFAULT, July 16, 2001 A.D. 14 www.supremelaw.org/copyrite/msen.com/default1.htm 15 16 “L” COVER LETTER, NOTICE OF LAWSUIT AND REQUEST FOR WAIVER OF SERVICE 17 OF SUMMONS, and federal Clerk’s notice changing docket number 18 www.supremelaw.org/cc/aol/cover.letter.htm 19 www.supremelaw.org/copyrite/msen.com/request.for.waiver.htm 20 www.supremelaw.org/cc/aol/order.2001-08-01/order01.gif 21 22 “M” copies of federal SUMMONS IN A CIVIL CASE, RETURN OF SERVICE, 23 U.S. Postal Service Delivery Confirmation Receipt, and USPS 24 Shipment History #0301 0120 0007 0064 3353 25 www.supremelaw.org/copyrite/msen.com/summons.gif 26 www.supremelaw.org/copyrite/msen.com/summons.proof.gif 27 28 “N” copy of letter dated Jan. 25, 2002 from Kiernan F. Cunningham, 29 Strobl Cunningham Caretti & Sharp, and draft NOTICE OF VOLUNTARY 30 DISMISSAL with Plaintiff’s annotation: “REFUSED FOR CAUSE” 31 32 “O” SUBPOENA IN A CIVIL CASE, DEMAND FOR SUBSCRIBER IDENTITY dated 33 Dec. 4, 2001 A.D., and PROOF OF SERVICE: 34 www.supremelaw.org/copyrite/msen.com/subpoena.gif 35 www.supremelaw.org/copyrite/msen.com/subid2.htm 36 www.supremelaw.org/copyrite/msen.com/subpoena.proof.gif 37 38 “P” NOTICE OF JUDICIAL DEFAULT, dated Feb. 1, 2003 A.D. 39 www.supremelaw.org/copyrite/msen.com/judicial.default.htm 40 41 “Q” FIRST ADJUSTED INVOICE to Msen, Inc., Jan. 15, 2003 A.D.: 42 www.supremelaw.org/copyrite/msen.com/invoice1.htm 43 44 “R” NOTICE OF INTENT TO SUE FOR RACKETEERING AND RELATED CLAIMS, 45 to Msen, Inc., January 20, 2003 A.D.: 46 www.supremelaw.org/copyrite/msen.com/intentsue.rico.htm 47 48 “S” SECOND ADJUSTED INVOICE to Msen, Inc., Aug. 1, 2003 A.D.: 49 www.supremelaw.org/copyrite/msen.com/invoice2.htm 50 51 “T” Exhibits N-124 and N-136 (repeated for convenience of MSEN/Meyer)

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 3 of 30 1 Plaintiff now replies in sequence to each of MSEN’s affirmative

2 defenses:

3 REPLY TO FIRST AFFIRMATIVE DEFENSE

4 Plaintiff’s COMPLAINT and each cause of action stated therein do

5 state facts sufficient to constitute a cause of action against MSEN.

6 See verified evidence in all Attachments incorporated supra, and in

7 all Exhibits formally incorporated in Plaintiff’s Initial COMPLAINT.

8 9 REPLY TO SECOND AFFIRMATIVE DEFENSE

10 No allegations or causes of action in the COMPLAINT are barred by

11 any applicable statutes of limitation. MSEN’s failure to answer a

12 proper and lawful SUBPOENA IN A CIVIL CASE, issued and served pursuant

13 to 17 U.S.C. 512(h), implicates obstruction of justice and hindering

14 the apprehension and prosecution of all subscribers suspected of

15 committing RICO predicate acts against Plaintiff. “Pattern of

16 racketeering” is defined to mean any two (2) predicate acts committed

17 during any given ten (10) year period. All events in question are

18 alleged to have occurred subsequent to March 12, 1993 A.D. (i.e. ten

19 (10) years prior to commencement of this action). See 18 U.S.C. 1961

20 et seq.

21 22 REPLY TO THIRD AFFIRMATIVE DEFENSE

23 Plaintiff has made every possible effort to mitigate his damages,

24 and damages against MSEN should not be barred or limited. For

25 example, Plaintiff went to extraordinary lengths to prepare and

26 transmit his Copyright Amnesty Program to MSEN. See Attachment “E”.

27 MSEN likewise failed to reply to that Copyright Amnesty Program.

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 4 of 30 1 REPLY TO FOURTH AFFIRMATIVE DEFENSE

2 Plaintiff is not barred from seeking relief against MSEN due to

3 any equitable doctrine of laches. Plaintiff has not neglected or

4 omitted to assert any of his Rights at issue here. On the contrary,

5 Plaintiff has expressly reserved All Rights on the caption pages of

6 all pleadings. That reservation is sufficient. The sheer number and

7 extent of racketeering predicate acts committed against Plaintiff by

8 all named Defendants has created extraordinary burdens for Plaintiff.

9 It was never Plaintiff’s obligation to police the Internet.

10 11 REPLY TO FIFTH AFFIRMATIVE DEFENSE

12 Plaintiff is not barred from seeking relief against MSEN due to

13 any equitable doctrine of estoppel. Plaintiff has never knowingly,

14 intentionally or voluntarily adopted any inconsistent positions,

15 attitudes or courses of conduct to the obvious detriment of MSEN.

16 17 REPLY TO SIXTH AFFIRMATIVE DEFENSE

18 Plaintiff is not barred from seeking relief against MSEN due to

19 any equitable doctrine of unclean hands. Plaintiff categorically

20 denies having unclean hands for any reasons in this case. On the

21 contrary, Plaintiff has gone to extraordinary lengths to maintain a

22 consistent posture of full and honest disclosure, and conscientious

23 compliance with all applicable laws, at all times and places.

24 25 REPLY TO SEVENTH AFFIRMATIVE DEFENSE

26 Plaintiff is not barred from seeking relief against MSEN due to

27 any knowing, intentional or voluntary waiver of any rights or claims.

28 On the contrary, Plaintiff has never knowingly, intentionally or

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 5 of 30 1 voluntarily waived any rights at issue here. Waivers of fundamental

2 Rights can never be presumed.

3 4 REPLY TO EIGHTH AFFIRMATIVE DEFENSE

5 Damages caused to Plaintiff were caused by acts and omissions of

6 MSEN, and not only by persons and entities other than MSEN. For

7 example, MSEN’s failure to register an Agent for Notification of

8 Copyright Infringement Claims was a deliberate omission. That

9 omission now bars MSEN from claiming any of the statutory immunities

10 that are available to all Internet Service Providers (“ISP”) who did

11 comply in good faith with the federal copyright laws in this regard.

12 See the controlling federal statute at 17 U.S.C. 512, in chief.

13 14 REPLY TO NINTH AFFIRMATIVE DEFENSE

15 As an ISP, MSEN did have a specific legal obligation to disclose

16 the identities of all subscribers suspected of infringing Plaintiff’s

17 exclusive copyrights, particularly after being served with a proper

18 civil SUBPOENA for such suspects’ identities. MSEN’s failure to do so

19 implicates obstruction of justice and hindering the apprehension and

20 prosecution of those subscribers. As an ISP, MSEN also had a legal

21 obligation to police the Internet; it was never Plaintiff’s

22 obligation to police the Internet. See Exhibit L -11, in chief, for

23 responsibilities of ISP’s, and Attachment “J” for court authorities

24 pertinent to discovery of racketeering evidence.

25 26 REPLY TO TENTH AFFIRMATIVE DEFENSE

27 Plaintiff has suffered extensive damages that are recoverable

28 from MSEN et al. as a matter of fact and law. The civil RICO statute

29 at 18 U.S.C. 1964 authorizes this court to award triple damages to

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 6 of 30 1 Plaintiff for all damages sustained in connection with all

2 racketeering activities and with all predicate acts committed to

3 further the racketeering enterprise properly alleged in Plaintiff’s

4 Initial COMPLAINT.

5 6 REPLY TO ELEVENTH AFFIRMATIVE DEFENSE

7 MSEN’s actions and omissions were not all reasonable or justified

8 under the circumstances, nor were they always committed in the

9 exercise of good faith or with sufficient probable cause.

10 11 REPLY TO TWELFTH AFFIRMATIVE DEFENSE

12 MSEN’s actions and omissions were not committed in the exercise

13 of a good faith reliance upon the acts of others. MSEN can not claim

14 ignorance of the applicable State and federal laws. MSEN’s retained

15 an unlicensed attorney to represent it in the federal case. It was

16 never Plaintiff’s obligation actively to police unlicensed attorneys.

17 MSEN also failed to disclose evidence that it had delegated any powers

18 of attorney to unlicensed attorneys. Plaintiff was entitled to expect

19 that MSEN and its agents were obeying all applicable State and federal

20 laws at all times. See Exhibit M -4.

21 22 REPLY TO THIRTEENTH AFFIRMATIVE DEFENSE

23 None of Plaintiff’s claims and causes of action in the COMPLAINT

24 against MSEN is barred, in whole or in part, by any conduct of

25 Plaintiff, and none is barred by the conduct of any of Plaintiff’s

26 agents, representatives or material witnesses. In point of fact,

27 Plaintiff had no “employees” as such during the period in question.

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 7 of 30 1 REPLY TO FOURTEENTH AFFIRMATIVE DEFENSE

2 The causes of action in the COMPLAINT against MSEN are not barred

3 for any reason, because MSEN and its officers, employees and contract

4 agents did breach their duty to obey all pertinent laws at all times.

5 6 REPLY TO FIFTEENTH AFFIRMATIVE DEFENSE

7 The damages caused to Plaintiff by MSEN were caused by persons

8 and entities that are also named Defendants in this action. MSEN did

9 have control over some of those Defendants. See Attachment “G”, and

10 Exhibit L -11 in particular (enumerating affirmative obligations of

11 ISP’s). MSEN is not entitled to indemnity from these other

12 Defendants. Respondeat superior. See also Exhibit N -124.

13 14 REPLY TO SIXTEENTH AFFIRMATIVE DEFENSE

15 Plaintiff’s federal case was not dismissed, in part because there

16 is no Presidential Commission in evidence for Messrs. Dale A. Drozd,

17 William B. Shubb or Stephen S. Trott. Moreover, the United States

18 District Court lacked original jurisdiction over the initial complaint

19 in Plaintiff’s federal case. See 60 Stat. 440, as fully discussed in

20 Plaintiff’s PETITION FOR WRIT OF CERTIORARI TO THE NINTH CIRCUIT,

21 docketed by the Clerk of the Supreme Court of the United States on

22 June 27, 2003 A.D. This latter PETITION has also been filed in the

23 instant case as the SECOND SUPPLEMENT TO MOTION TO BAR REMOVAL in

24 support of Plaintiff’s MOTION FOR PRELIMINARY INJUNCTION BARRING

25 REMOVAL INTO FEDERAL COURT. Plaintiff’s DEMAND FOR RULING on same is

26 now outstanding.

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 8 of 30 1 REPLY TO SEVENTEENTH AFFIRMATIVE DEFENSE

2 MSEN may not raise additional defenses to the COMPLAINT, based

3 upon subsequent investigation of this litigation, due to the fact that

4 MSEN’s answer was not timely, and MSEN is now in default.

5

6 WHEREFORE, defendant MSEN is not entitled to any of the relief

7 requested in its untimely answer.

8

9

10 VERIFICATION

11 The Undersigned hereby verifies, under penalty of perjury, under

12 the laws of the United States of America, without the “United States”

13 (federal government), that the above statement of facts and laws is

14 true and correct, according to the best of his current information,

15 knowledge and belief, so help me God, pursuant to 28 U.S.C. 1746(1).

16 See Supremacy Clause in the Constitution for the United States of

17 America, as lawfully amended, i.e. Constitution, Laws and Treaties of

18 the United States are all the supreme Law of this Land.

19

20

21 Dated: July 21, 2003 A.D.

22

23 Signed: /s/ Paul Andrew Mitchell 24 ______25 Printed: Paul Andrew Mitchell, B.A., M.S., Sui Juris

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 9 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “A”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 10 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “B”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 11 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “C”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 12 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “D”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 13 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “E”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 14 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “F”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 15 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “G”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 16 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “H”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 17 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “I”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 18 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “J”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 19 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “K”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 20 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “L”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 21 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “M”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 22 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “N”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 23 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “O”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 24 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “P”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 25 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “Q”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 26 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “R”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 27 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “S”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 28 of 30 1 2 3 4 5 6 7 8 9 10 11 Attachment “T”: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 29 of 30 1 PROOF OF SERVICE

2 I, Paul Andrew Mitchell, Sui Juris, hereby certify, under penalty of

3 perjury, under the laws of the United States of America, without the

4 “United States” (federal government), that I am at least 18 years of

5 age, a Citizen of ONE OF the United States of America, and that I

6 personally served the following document(s):

7 8 PLAINTIFF’S REPLY TO ANSWER 9 OF DEFENDANT MSEN, INC.: 10 18 U.S.C. 1964; CCC 22.2 11 (common law is rule of decision) 12 13 by placing one true and correct copy of said document(s) in first

14 class United States Mail, with postage prepaid and properly addressed

15 to the following:

16 17 Msen, Inc. 18 c/o Lawrence F. Meyer 19 500 North Brand Blvd., Suite 920 20 Glendale 91203 21 CALIFORNIA, USA 22 23 24 [Please see USPS Publication #221 for “addressing” instructions.] 25 26 27 28 Dated: July 21, 2003 A.D. 29 30 31 Signed: /s/ Paul Andrew Mitchell 32 ______33 Printed: Paul Andrew Mitchell, B.A., M.S., Sui Juris

1 Plaintiff’s Reply to Answer of Defendant Msen, Inc.: 2 Page 30 of 30