Thursday, May 14, 2009

THE DR. SEUSS LAWSUIT or HOW J. TONY SERRA SOLD ME OUT - by Charles Augustus Steen III

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO



CHARLES AUGUSTUS STEEN III
Plaintiff

v. No. CIV-07-1004 MV ACT

J. TONY SERRA, AUDREY GEISEL,
KARL ZOBELL, CATHY ANN
BENCIVENGO, JANET SCHULMAN,
JUDY BRUNSTAD, TIM CURRY,
W.E. “SKIP” STEPHENSON,
WILLIAM M. LANSDOWNE,
RICHARD SERRA, ERIN O’DONNELL,
CHARLES C. EDWARDS, DAVID
COPLEY, HERB CHEYETTE, STEVEN
PAUL LEVIA, JOSEPH ROSE,
LAKE PERRIGUEY & John Does (1-10)
First Party Defendants

and

Pier 5 Law Offices, Dr. Seuss Enterprise, Inc.,
Random House, The Institute of Children’s
Literature, The San Diego Police Department,
The Oregonian, Collingwood O’Hare
Entertainment Ltd & John Does (1-10)
Second Party Defendants








Table of Contents
I: NATURE OF THE CASE
(a): First Party Defendants and their relations.
(b): Second Party Defendants and their relations.
II: EXHIBITS A through J
A: HOW C. JUDITH ‘JUDY’ BRUNSTAD
DID KNOWINGLY AND WILLFULLY ALLOW FOR
DR. SEUSS ENTERPRISES TO COMMITTEE
PARAPHASE PLAGIARISM REGARDING
MISSAPPROPRIATION OF IDEAS AND CREATIVE
LANGUAGE 17 U.S.C. 102 (a).

B: HOW AUDREY GEISEL, JANET SCHULMAN &
TIM CURRY DID WILLFULLY AND
KNOWINGLY COMMITTE FRAUDULENT
COPYRIGHT NOTICE 17 U.S.C. 506 (c), CRIMINAL
INFRINGMENT 18 U.S.C. 2319; REGUARDLING
INFORMATION FROM THE LIBRARY OF CONGRESS.

C: HOW AUDREY GEISEL AND KARL ZOBELL
COMMITTED SUBORNATION OF PERJURY 18 U.S.C.
1622, FRAUD & FALSE STATEMENTS 18 U.S.C. 1016
in order to stop me from my limitations on actions 17 U.S.C.
507 (a)(b) being that DSE committed an offense under
17 U.S.C. 506 (d)(1)(A).

D: HOW W.E. “SKIP” STEPHENSON COMMITTED
11 COUNTS OF PERJURY & OBSTRUCTION OF
JUSTICE 28 U.S.C. 1746, 18 U.S.C 1505, 18 U.S.C. 1510 (b).

E (i through ix): HOW J. TONY SERRA, AUDREY GEISEL,
RICHARD SERRA, KARL ZOBELL, ERIN O’DONNELL,
CHARLES C. EDWARDS & DAVID
COPELY COMMITTED RACKETEERING:
18 U.S.C. 893, 18 U.S.C. 1956 (3)(A)(B), BRIBERY
& CONFLICTS OF INTEREST: 18 U.S.C. 280
(THE STATE BAR OF CALIFORNIA
INQUIRY NUMBER 05-11183).



F: HOW CATHY ANN BENCIVENGO DID
KNOWINGLY AND WILLFULLY COMMIT
PERJURY 28 U.S.C. 1746

G: HOW ERIN O’DONNELL DID KNOWINGLY
AND WILLFULLY ASSIST IN THE COVER UP
OF DAISY-HEAD MAYZIE FOR MISPRISION
OF FELONY 18 U.S.C. 4 & RELATING TO
OBSTRUCTION OF CRIMINAL INVESTIGATION
18 U.S.C. 1510 (3)(A).

H: HOW HERB CHEYETTE & STEVEN PAUL LEVIA
COMMITTED COUNTERFEITING AND FORGERY
OF FICTITIOUS OBLIGATIONS 18 U.S.C. 514 (a)(1)(2)
Regarding the lost work of Dr. Seuss in order to stop me from
My limitations on actions 17 U.S.C. 507 (a)(b) being that
DSE committed an offense under 17 U.S.C. 506 (d)(1)(A).

I: HOW LAKE PERRIGUEY, DID KNOWINGLY
AND WILLFULLY ASSIST IN THE COVER UP
OF DAISY-HEAD MAYZIE FOR MISPRISION OF
FELONY 18 U.S.C. 4 & RELATINGTO
OBSTRUCTION OF CRIMINAL INVESTIGATION
18 U.S.C. 1510 (3)(A).

J: HOW JOSEPH ROSE OF THE OREGONIAN
DID SO KNOWLINGLY AND WILLFULLY COMITTE
ACTUAL MALICE REGARDING LIBEL DEFAMATION
OF CHARCTER 28 U.S.C. 2680 (h).

III: INFORMATION FROM THE LIBRARY OF CONGRESS

IV: LIST OF PLAGIARIZED COMPARISIONS

V: EXAMPLE OF PLAGIARIZED TEXTUAL EXPRESSION

VI: STATEMENTS FROM AUDREY GEISEL & KARL ZOBELL

VII: REQUEST FOR RELIEF






NATURE OF THE CASE: First Party Defendants and their relations.
This case regards, corruptus in extremis, being that the Plaintiff’s former attorney J. Tony Serra with the help of Audrey Geisel and fourteen individuals along with five corporations have committed crimes of monumental proportions; with respect to conspiracy against civil rights 18 U.S.C. 0241, fraud and false statements 18 U.S.C. 1OO1, 26 U.S.C. 7206, obstruction of justice 18 U.S.C. 1512, perjury 18 U.S.C. 1621, 28 U.S.C. 1746, misprision of felony 18 U.S.C. 0004, bribery 18 U.S.C. 0152, 18 U.S.C. 201 and racketeering 18 U.S.C. 1957 in regards to the plagiarizing and cover up of the Plaintiff’s children’s story “The Pains of Being Pure at Heart” TXu-500-969 and the ‘lost work of Dr, Seuss’ a.k.a. “Daisy-Head Mayzie” a.k.a. ‘a newly found treasure’ TX-4-042-306.
This case is not a simple copyright infringement case as was Civil Case 1:01-cv-0211 which was dismissed without prejudice, this case regards concealment of causes from public knowledge from powerful and respected individuals and their organizations in order to distort the truth.
This case is that of 18 U.S.C. 241 and 28 U.S.C. 2501 due to the fact that everyone involved; foremost Audrey Geisel, Karl ZoBell, Cathy Ann Bencivengo and W. E. “SKIP” Stephenson LIED to have the Plaintiff arrested on November 5th 2003 on false charges of extortion regarding the date in which Civil Case 1:01-cv-0211 was dismissed JUNE 18th 2003, 793 days after BENCIVENGO emailed STEEN on APRIL 16th 2001 and the original request of relief of $2,500,250.50. The statute of limitations expires on November 5th 2009.
Under normal circumstances there would be three lawsuits: one against Dr. Seuss Enterprises L.P. and The Institute of Children’s Literature for copyright infringement, one against The San Diego Police Department and W.E. “SKIP” Stephenson for wrongful arrest and obstruction of justice and one against J. Tony Serra for malpractice and conflicts of interest; yet due to the fact that all of these individuals worked together in order to conceal evidence regarding the Plaintiff’s original Civil Case 1:01-cv-0211 and its outcome; this is a new case altogether. Without all of the Defendants in question the true nature of the case could be concealed, and thus the facts here in presented could be distorted and misconstrued. Without all the pieces of the puzzle the picture as a whole would not be seen accurately. Here are all the pieces.
On May 17th 1992 the Plaintiff received a letter from the Institute of Children’s Literature informing him of his acceptance regarding “The Pains of Being at Heart” signed C. Judith Brunstad (the letter is the fundamental piece of evidence regarding this case).
The Institute of Children’s Literature is affiliated with Random House who publishes Dr. Seuss. The Institute of Children’s Literature is only a few miles away from the Groiler Company who also publish Dr. Seuss. C. Judith Brunstad lives 5 miles away from The Institute of Children’s Literature and was the Director of Admissions at the time. C. Judith Brunstad and her husband George Brunstad are very well respective individuals in their community; they were friends with Alvin Tresselt (now deceased) who was a friend of Audrey Geisel and Theodore Seuss Geisel a.k.a Dr. Seuss (now deceased).
On MAY 17th 1994 the article in The Orange County Register entitled “A Legacy from Dr. Seuss” was the first mention of “DAISY-HEAD MAYZIE”.
The first dismissed without prejudice case was filed Civil Case 1:01-cv-0211 on FEBRUARY 22ND 2001. Pro Se. The case was dismissed without prejudice by the Honorable Judge Don Svet JUNE 18th 2003.
The second dismissed without prejudice case was filed December 12th 2001, Case # 01-CV-1800-KI. Pro Se and was dismissed without prejudice by the Honorable Garr M. King, June 13th, 2002. It is the Plaintiff’s belief that DSE were unaware of the second case because they were never served. It was (and is) safe at the Mark O. Hatfield United States Federal Court House.
Regarding the first dismissed without prejudice case; it is the Plaintiff’s belief that DSE was going to settle with him in 2001 being that DSE hired Mordall. Sperling, Harris & Sisks in ABQ, NM to represent them.
DSE and the Defendants are aware of the facts regarding their fake Dr. Seuss book; being that Audrey GEISEL, Janet SCHULMAN and Tim CURRY DID WILLFULLY AND KNOWLING COMMIT FRAUDULENT COPYRIGHT NOTICE 17 U.S.C. 506 (c) and CRIMINAL INFRINGMENT 18 U.S.C. 2319. CUI PRODEST IS FACIT.
In August of 2001 Brian FORBES, who was an attorney representing DSE and the Gray-Cary Law Firm sought assistance from the FBI in New Mexico, the situation being reviewed by Sylvia MARUFFI an FBI Investigative Analyst. The information was forwarded to the U.S. Attorney’s Office and they declined to pursue prosecution.
Nonetheless, on NOVEMBER 5th 2003 the Plaintiff was falsely arrested by W. E. “SKIP” Stephenson of the San Diego Police Department, in Portland Oregon, on perjured evidence by the real guilty party and their accomplices with their fabrication of evidence and editing of evidence. The Plaintiff was arrested at 10:45 am yet the search warrant was not filed until 5:12 pm. The Plaintiff spent eight days in the Justice Center. The Plaintiff was released on a $100.000.00 bail.
The Plaintiff hired Mr. J. Tony SERRA (currently on probation for tax evasion 26 U.S.C. 7201), for the sum of $10,000.00 to represent him on my TWO COUNTS of EXTORTION, by borrowing money from his friends James BEUHRING and Steven YANG. Mr. J. Tony SERRA informed the Plaintiff that it did not matter that DSE had plagiarized his children’s story nor that W.E. “SKIP” STEPHENSON committed eleven counts of PERJURY 18 U.S.C 1505 and OBSTRUCTION OF JUSTICE 28 U.S.C. 1746 and that the evidence was of no importance.
The Plaintiff hired Lake Perriguey on December 17th 2003 to represent him on the civil matters of the case. Lake Perriguey did nothing for his client for 104 days and never returned his clients evidence.
On March 2nd, 2004 the Plaintiff plead guilty of extortion from the Dr. Seuss Estate in San Diego with the Honorable Frederick Maguire presiding. J. Tony Serra acted as his attorney. The Complaint was filed by Audrey Geisel ‘the widow of Dr. Seuss”, Karl ZoBell, Cathy Bencivengo and the Gray Cary Ware & Freidenrich Law Firm. Count One: April 16th 2001 to July 24th 2003. Count Two: August 18th 2003 to September 9th 2003.
The Plaintiff was led to believe that he was pleading to Count Two, not Count One, because (a), Civil Case 01-0211 was not dismissed until 6-18-2003 and (b), he did not try to attempt an out of court settlement for the sum of $250,000.00 from The National Endowment of the Arts, through Jessica Padilla at the La Jolla Playhouse, and that Tim Curry should buy his Seuss parody painting for the sum of $50,000 on August 18th 2003, This e-mail was sent to Jessica Padilla; the Subject: DID YOU KNOW Dr. Seuss Enterprises PLAIGARIZED DAISY-HEAD MAYZIE?? READ THIS!! . The Plaintiff was under the impression Count One was dropped because all of the facts and dates were distorted and completely incorrect. The plea agreement was “Threatening to EXPOSE Audrey Geisel to disgrace”, The Plaintiff realized it was a stupid move, he didn’t listen to himself, and that alone was the mistake he made.
NOTE: In both counts the Defendants claim the Plaintiff made written threats of extortion to Audrey Geisel; The Plaintiff never contacted Audrey Geisel whatsoever. It was Karl ZoBell with whom The Plaintiff e-mailed his play to on September 9th 2003. It was Karl ZoBell whom he was trying to negotiate an out of court settlement. Karl ZoBell and Audrey Geisel have committed false statements regarding title 17 U.S.C. 501 (a)(1)(2)(c)(e). The Plaintiff was simply taking a firm stance against a powerful corporation. Never did the Plaintiff distort the facts or lie. Copyright infringement is five years in prison and a $250,000 fine per infringement, under section 2319 of title 18.
On March 1st 2004 the Plaintiff was ready to plea NOT GUILTY, but on the 2nd in the hallway outside of the courtroom Mr. Serra and Mrs. O’Donnell informed the Plaintiff they needed another $10,000.00 to go to trial. They knew he had no money. Mr. J. Tony Serra also stated that there was no way he would receive a fair trial being that Audrey Geisel was a major philanthropist in San Diego. Mr. Serra talked the Plaintiff into a coerced confession of talking a guilty plea. He did not even inform the Plaintiff of taking a plea of ‘no contest’. He did not inform the Plaintiff of a pretrial and they claimed that the Plaintiff’s evidence of copyright ownership was of no importance. Mr. J. Tony Serra told the Plaintiff he was guilty of threatening to exposing the truth.
Mr. J. Tony Serra’s brother Richard Serra received the sum of a $1.000.000.00 grant from Dr. Charles C. Edwards and wife Sue K. Edwards for a sculpture to be placed at the Museum of Contemporary Arts San Diego in 2006. Mrs. Audrey Geisel/Dr. Seuss Foundation donated $25,000 - $49,999, Gray Cary Ware & Freidenrich donated $5,000 – 9,999, Sue K. and Charles C. Edwards donated $50,000 - $99,999 to the Museum of Contemporary Arts San Diego.
Mr. J. Tony Serra informed the Plaintiff that his eleven page Arrest Warrant Argument and Rebuttal must not be presented to the Honorable Joseph Maguire.
Mr. J. Tony Serra refused to contact the Plaintiff regarding his 18 months probation and returning to San Diego for having his sentence be reduced to a misdemeanor. Mr. J. Tony Serra’s secretary informed the Plaintiff that Mr. Serra was no longer his attorney. The Plaintiff has not received any of his property from Mr. Serra’s Law Firm. Mr. J. Tony Serra has never sent the Plaintiff a breakdown of his legal fees. It is the Plaintiff’s understanding that under the Rules of Procedure of the State Bar of California TITLE IV. STANDARDS FOR ATTORNEY SANCTIONS FOR PROFESSIONAL MISCONDUCT, Mr. J. Tony Serra should be held accountable of 2.3 OFFENSES INVOLVING MORAL TURPITUDE, FRAUD, DISHONESTY OR CONCEALMENT. Culpability of a member of an act of moral turpitude, fraud, or intentional dishonesty toward a court, client or another person or of concealment of a material fact to a court, client or another person shall result in actual suspension or disbarment depending upon the extent to which the victim of the misconduct is harmed or misled and depending upon the magnitude of the act of misconduct and the degree to which it relates to the member's acts within the practice of law.
It is the Plaintiff’s understanding that under the Rules of Procedure of the State Bar of California TITLE IV. STANDARDS FOR ATTORNEY SANCTIONS FOR PROFESSIONAL MISCONDUCT, Mr. J. Tony Serra should be held accountable of 2.4 OFFENSES INVOLVING WILFUL FAILURE TO COMMUNICATE WITH THE CLIENT OR TO PERFORM SERVICES IN THE MATTER FOR WHICH THE MEMBER HAS BEEN RETAINED. Culpability of a member of a pattern of willfully failing to perform services demonstrating the member's abandonment of the causes in which he or she was retained shall result in disbarment. http://calbar.ca.gov/calbar/html_unclassified/3r-t4-p2.htm#24
During the hearing no dates or amounts were ever mentioned. The Plaintiff was told it was 18 months probation and then he would be off the hook. The prosecutor Tonya Price and his legal counsel seem to have completely deceived the Honorable Joseph Maguire.
The Plaintiff’s record was expunged April 17, 2006 by Stephanie Sontag Judge of the Superior Court San Diego County, CA. The Plaintiff’s lawyer was Michael T. Maloney substituting for J. Tony Serra.
On August 4th 2006 DSE missed the five year statute of limitation to sue Mr. STEEN for his Dr. Seuss parody painting under 18 U.S.C. 3282. DSE knew regardless that under “fair use” STEEN’s painting was indeed a parody.
On May 1st 2007 The Plaintiff stood up for his First Amendment Rights and produced his play THE TRAGICAL HISTORY OF AUDREY GEISEL at the Someday Lounge in Portland, Oregon, with overwhelming success. The Plaintiff invited members of the press to witness his slideshow presentation of evidence proving that he was indeed plagiarized, falsely arrested, how his Forth Amendment Rights were abused and his being sold out by his attorney Mr. J. Tony Serra. The Plaintiff then invited the FBI in Portland, Oregon to watch the play on May 8th 2007. On the 8th of May 2007, in The Oregonian in the Living Section, Lynda Claassen, director of the Mandeville Special Collections Library at the University of San Diego stated “What we have for Daisy-Head Mayzie are 1950s Photostats of Drawings, but no text.” Thus proving, Audrey Geisel never found a manuscript in the bottom of a drawer after her husband’s death in 1991.
The First Party Defendants being Audrey Geisel, and her 16 cohorts, have done so knowingly and willingly committed perjured evidence by the real guilty party and their accomplices through the use of police misconduct and the editing of evidence, the neglect and incompetence of the Plaintiff’s legal counsel, the abuse of process, the false imprisonment, the Plaintiff’s false confession due to police pressure and psychological weakness and the Plaintiff’s legal counsel withholding evidence, regarding quid pro quo dealings of 18 U.S.C. 893 and 18 U.S.C. 280.
This case of civil remedies of restitution in integrum regarding the decrease in standard of living due to the injuries suffered and the pain and suffering and emotional stress from probation, community service and anger management, character assassination, the negligence and breach of contract with the Plaintiff’s former attorneys through illicit reckerting regarding CUI PRODEST SCELUS IS FACIT. 28 U.S.C. 2255, 18 U.S.C. 1964 (c ) (d), not only for copyright infringement but for the stress they have caused the Plaintiff and the damage to his reputation brought about by the Defendants with their combined criminal abuse of power regarding 18 U.S.C. 241 and 28 U.S.C. 2501.

NATURE OF THE CASE: Second Party Defendants and their relations
Pier 5 Law Offices is the law office of J. Tony Serra who acted as the attorney for the Plaintiff. Dr. Seuss Enterprise, Inc. and Random House publish and market the work of Dr. Seuss. The Institute of Children’s Literature is affiliated to Random House. The San Diego Police Department is responsible for the conduct of its officers i.e. W. E. ‘SKIP’ Stephenson and The Oregonian is the news paper which committed malice and liable in regards to the Plaintiff’s reputation.
COINCIDENCE IS ONE THING while CONNECTIONS ARE ANOTHER.
CONSUMMATUM ET CONCORDIA CUM VERITATE. DIXI.






EXHIBIT A
A: HOW C. JUDITH ‘JUDY’ BRUNSTAD DID KNOWINGLY AND WILLFULLY ALLOW FOR DR. SEUSS ENTERPRISES TO COMMIT PARAPHASED PLAGIARISM REGARDING MISSAPPROPRIATION OF IDEAS AND CREATIVE LANGUAGE 17 U.S.C. 102 (a).

.CASE NO: 01-CV-1800-KI, (B,B.a) LETTER:
May 17th, 1992. Dear Mr. Steen, We are delighted to inform you that your Aptitude Test has qualified you for enrollment in our course. We were impressed with your essay “The Pains of Being Pure at Heart” and found that your responses to the other questions show promising insight and the essential ability to write for children. We want you to know that we are not publishers, nor are we affiliated with any publishers. We are a school, and our instructors teach our students how to write for children and how to assess and approach the publishing market. I noted your interest in illustrations and wanted to let you know that we advise our students to submit manuscripts without accompanying illustrations. Very frequently illustrations will limit the vision of the editor and thus detract from the manuscript’s chance to meet that editor’s requirement for acceptance. Choosing an illustrator for an accepted manuscript is the publisher’s prerogative and one that is quite jealously guarded. Please let me know if I may be of any further assistance. Sincerely, C. Judith Brunstad, Director of Admissions.

NOTE, http://institutechildrenslit.com/instructors.html, clearly shows the publishers associated to The Institute of Children’s Literature. Bantam Books is a part of Random House.

EXHIBITE B

HOW AUDREY GEISEL, JANET SCHULMAN & (the actor) TIM CURRY DID WILLFULLY AND KNOWINGLY COMMIT FRAUDULENT COPYRIGHT NOTICE 17 U.S.C. 506 (c), CRIMINAL INFRINGMENT 18 U.S.C. 2319

FACT: “The Pains of Being Pure at Heart” was created between January 8th-15th 1990. It was registered TXu-500-969 on June 21st 1991.

FACT: “Daisy-Head Mayzie” book was created 1991, Published December 30th 1994 and registered TX-4-042-306 on April 10th 1995.

FACT: “Daisy-Head Mayzie” animated television special was created 1994. Published February 5th 1995 and registered PA-700-090 on May 1st 1995.

FACT: In “Daisy-Head Mayzie” book it claims: BASED ON THE ANIMATED TELEVISION SPECIAL Daisy-Head Mayzie.

IMPORTANT FACT: It is IMPOSSIBLE for the “Daisy-Head Mayzie” book to be based on the animated television special, being that the animated television special is created, published and registered after the book; according to the Library of Congress.

FACT: Tim Curry is credited as the author of “Daisy-Head Mayzie”

FACT: The first mention of ‘Daisy-Head Mayzie was May 17th 1994 ‘A Legacy from Dr. Seuss’ in The Orange County Register which states: Audrey Geisel, the author’s widow found the script in the bottom of a drawer as she was preparing to renovate her house in La Jolla. The article also states: Dr. Seuss wrote the story as a screenplay, he used typically whimsical verse and supplied a complete set of original drawings.

FACT: Jess Cagle wrote: She volunteers this information to avoid the rap that she’s exploiting Seuss and explains that by creating trademarks in various media, she’s protecting her husband’s creations. Yet some of (Audrey) Geisel’s decisions, notably to publish some material that her notoriously perfectionist husband left unpublished, are difficult even for her to explain. TIME Magazine ‘Seuss On The Loose’ Nov 20th, 2000.

LIE: Additionally, two books were published after his (Dr. Seuss’s) death, based upon preliminary drafts done while he was alive, but never finished by him. STATEMENT FROM AUDREY GEISEL 4-22-04

IMPORTANT FACT: Six books were produced posthumously!! “Daisy-Head Mayzie’ in 1994 by Tim Curry, ‘My Many Colored Days’ in 1996 by Stephen T. Johnson and Lou Fancher., ‘Hooray for Diffendoofer Day!’ in 1998 by Lane Smith and Jack Prelutsky., ‘Gerald McBoing Boing’ in 2000 by Mel Crawford., ‘The Eye Book’ in 2001 by Joe Mathieu, ‘The Tooth Book’ in 2003 by Joe Mathieu.

FACT: In the book entitled “The Seuss, The Whole Seuss and Nothing but the Seuss” there is no mention whatsoever of Daisy-Head Mayzie.

FACT: (Cathy Ann) Bencivengo said the manuscript for "Daisy-Head Mayzie" was written in the 1960s, before Steen was born. "They're both written in a rhyming meter, but so what? They're very dissimilar," she said. "It's not a children's story by a long shot." Onell R. Soto UNION-TRIBUNE STAFF WRITER August 21, 2004

FACT: Judith Morgan (author of Dr. Seuss and Mr. Geisel) doesn’t know what became of those early “set aside attempts” and what was “ ‘found’ and published.” THE OREGONIAN, TUESDAY MAY 8TH, 2007

FACT: Lynda Claassen, “What we have for Daisy-Head Mayzie are 1950’s Photostats of drawings, but no text.” THE OREGONIAN, TUESDAY MAY 8TH, 2007




EXHIBIT C

HOW AUDREY GEISEL AND KARL ZOBELL COMMITTED SUBORNATION OF PERJURY 28 U.S.C. 1726, 18 U.S.C. 1622, FRAUD & FALSE STATEMENTS 18 U.S.C. 1016 in order to stop me from my civil actions regarding 17 U.S.C. 507 (a)(b) being that DSE committed an offense under 17 U.S.C. 506 (d)(1)(A).

“Additionally, two books were published after his death, based upon preliminary drafts while he was alive, but never finished by him.” STATEMENT OF AUDREY GEISEL TO THE COURT APRIL 22ND 2004

“Further, we, and Mr. Geisel’s agent (Herbert Cheyette) had clear proof that the Dr. Seuss book in question had been put to paper by him years before the Steen work was put together by him.”

After the law suit failed; Mr. Steen began a course of sending frequent emails to me, and my partner, Cathy Ann Bencivengo. STATEMENTS OF KARL ZOBELL TO THE COURT APRIL 22ND 2004

EXHIBIT D

HOW W.E. “SKIP” STEPHENSON COMMITTED 11 COUNTS OF PERJURY & OBSTRUCTION OF JUSTICE 28 U.S.C. 1746, 18 U.S.C 1505, 18 U.S.C. 1510 (b).

Declaration in support of arrest warrant Case No.: San Diego PD #03-063400, Crt. No.: CD178413, DA No.: ABB730, Signed: Wilton E. “Skip” Stephenson, Declarant

“I declare, on information and belief, that the forgoing is true and correct under penalty of perjury” pg. 31.

COUNT ONE: On page 1 lines 26-28 of Wilton E. Stephenson’s Declaration In Support of Arrest Warrant he writes: In 2001. Steen sued DSE in a New Mexico court but the suit was dismissed. “”HE THEN”” threatened to make public his allegations if he wasn’t paid $2,500,000.00

FACT: Mr. Steen filed his Civil Case 1:01-cv-0211 on FEBRUARY 22ND 2001. Mr. Steen filed his suit Pro Se representing himself. Soon after the defendants were served, Charles Steen was contacted first by Cathy Ann BENCIVENGO of the Gray Cary Law Firm, which represents Dr. Seuss Enterprises. Steen’s request for $2,500,250.50 was a reply to Cathy Ann Bencivegno’s request for offering what he thought would be adequate for an out of court settlement on APRIL 16, 2001. Mr Steen’s Civil Case 1:01-cv-0211 was not dismissed until JUNE 18th 2003, 793 days after BENCIVENGO and STEEN’S email exchange on APRIL 16th, 2001. Steen’s suit never went to trial and was dismissed without prejudice by the Honorable Judge Don J. Svet and the suit may be filed again at any time.

COUNT TWO: On page 2 lines 2-4 “SKIP” writes: In August 2003, STEEN contacted GEISEL’S attorneys and demanded $250,000.00 to prevent him from producing a play he wrote, portraying Audrey Geisel in obscene situations.

FACT: Mr. Steen emailed Jessica Padilla, NOT GEISEL’S attorneys. The Subject: DID YOU KNOW Dr. Enterprise PLAGIARIZED DAISY-HEAD MAYZIE??? READ THIS!! On page 10 lines 4-7 Mr. Steen wrote: I meant to make a deal under the table so that I get 250,000.00 from the National Endowment for the Arts for three plays of mine, ELYSIUM, TO THINK WHAT ONLY WEIRDOS DARE, and THEE TRAGIC MELLOW DRAMATIC DEATH OF DORIS DINGHY. The National Endowment for the Arts are not GEISEL’s attorneys. JESSICA PADILLA is the Public Relations Manager for the La Jolla Playhouse, a popular theatre in La Jolla, CA. Jessica PADILLA is not an attorney representing Audrey GEISEL. Jessica PADILLA is a personal friend of Karl and Barbara ZoBell. This email was sent to make a mockery of Karl ZoBell.

COUNT THREE: On page 2 lines 13-16 “SKIP” writes: “”After the suit was dismissed”””, STEEN sent an email to GEISEL’s attorneys and stated he would go public with his allegations unless 2,500,250.50 (after taxes) was deposited into his Wells Fargo bank account.

FACT: Mr. Steen filed his civil case 1:01-cv-0211 on FEBRUARY 22nd 2001. Mr. Steen filed his suit Pro Se representing himself. Soon after the defendants were served, Charles Steen was contacted first by Cathy Ann BENCIVENGO of the Gray Cary Law Firm, which represents Dr. Seuss Enterprises. Steen’s request for $2,500,250.50 was a reply to Cathy Ann Bencivengo’s request for offering what he thought would be adequate for an out of court settlement on APRIL 16th , 2001. Mr. Steen’s civil case 1:01-cv-0211 was not dismissed until JUNE 18th 2003, 793 days after BENCIVENGO and STEEN’s email exchange on APRIL 16th, 2001. Steen’s suit never went to trial and was dismissed without prejudice by Judge Don J. Svet and the suit may be filed again at any time.

COUNT FOUR: On page 2 lines 19-21 “SKIP” writes: He (ZOBELL) said STEEN also sent a photograph of a painting depicting some Dr Seuss characters involved in sexual behavior. He said STEEN Demanded he be paid $50,000 or he would go public with the artwork.

FACT: On August 4, 2001, STEEN emailed every lawyer at the Gray Cary law firm an attachment of a photograph of his painting depicting Seuss characters in sexual situations. Mr. Steen’s painting was created as a parody of ridiculing Dr. Seuss characters and titled: BEHIND THE SCENES OF DAISY-HEAD MAYZIE. The painting was created as a mockery toward Cathy Ann Bencivengo and DSE because of a ruling by Judge O’Scannlain in a Ninth Circuit case regarding Dr. Seuss Enterprises vs. Penguin Books, USA; stating: This decision is significant because it has clarified a coherent standard in copyright law for determining whether a potentially infringing work is a fair use parody. A parodist must ridicule the original composition or author in order for fair use to apply. Mr. Steen made such a parody therefore his painting was created under the terms of ‘fair use’.
This painting was created in order to use Judge O’Scannlain’s ruling in favor of Gray Cary to make a mockery of Dr. Seuss Enterprise, Dr. Seuss characters and the Gray Cary law firm. In the email sent to Gray Cary lawyers with the painting attached, there was no mention of making demands for $50,000 or any amount of money whatsoever. STEEN mentioned that the painting was due to be exhibited in Manhattan in January, 2002 however in that particular email, was no demand for any amount of money.

COUNT FIVE: On page 4 lines 18-19 “Skip” writes: (Jennifer) MAROSI found, through public records, that STEEN had an assault charge brought against STEEN in 1993.

FACT: Mr. Steen was not convicted and the charges were dropped.

NOTE: The ‘incident’ was over ten years ago and it was Mr. Steen who called the police because he was attacked by four individuals in his apartment.

COUNT SIX: On page 10 lines 9-11 of ‘SKIP’s” Declaration in support of Arrest Warrant, Mr. Steen wrote: I also demand that Tim Curry a.k.a. ‘the clown’ buy my painting of DAISY-HEAD MAYZIE for $50,000 plain and simple.

FACT: Tim Curry (one of the many ‘authors’ of Daisy-Head Mayzie) is not Audrey Geisel or an attorney for Gray Cary.

FACT: The date of the e-mail to Jessica PADILLA was Monday, August 18th, which was the second count of (the supposed) extortion; which was dropped.

FACT: This request was emailed to Jessica PADILLA, for the simple fact that she would research “Daisy-Head Mayzie” and learn that Tim Curry was one of the many authors of the ‘LOST WORK’ of Dr. Seuss. Mr. Steen had no intention of selling the painting to Tim Curry, the email was purely sarcastic. Mr. Steen was not in possession of the painting at that time. The painting was safe in Canada.

FACT: On page 2 lines 25-28 & page 3 lines 1-3 ‘SKIP’ writes: I learned, from reading an email from ZOBELL, from Brian FORBES, that assistance was sought from the FBI in New Mexico, in August 2001. ZOBELL explained that FORBES was an attorney representing the Gray-Cary and FORBES sought assistance ‘from several law enforcement agencies in stopping STEEN’s harassment of the law firm’s attorneys. FORBES’s email mentions the situation being reviewed by Sylvia MARUFFI an FBI Investigative Analyst. I learned from MARUFFI, that the information was forwarded to the U.S. Attorney’s Office and they declined to pursue prosecution.

IMPORTANT FACT: Sylvia MARUFFI, an FBI Investigative Analyst and ‘several enforcement agencies’ including the U.S Attorney’s Office declined to pursue prosecution. If the FBI declined to pursue prosecution, then why would any other law enforcement agency, such as the San Diego Police Department?

COUNT SEVEN: On page 6 ‘SKIP’ deleted an entire paragraph, which is missing from Cathy Ann Bencivengo’s email to Mr. Steen on Monday APRIL 16th , 2001. This email was a reply to Steen’s email regarding offering what he thought was an adequate out of court settlement in his civil case 1:01-cv-0211 filed n FEBRUARY 22nd 2001. STEEN’s civil case had not expired until JUNE 18th 2003 and was dismissed without prejudice having expired before going to trial 120 days after the initial filing. This paragraph clearly illustrates that STEEN was representing himself as his own attorney in his civil case and was attempting to reach an out of court settlement with DSE’s attorneys.

As you (Cathy Ann Bencivengo) said over the telephone that WE CAN RESOLVE THIS ISSUE WITHOUT GOING TO COURT, basically means SETTLE, because your client KNOWS I am in the (COPY) RIGHT. Well, that’s not good enough for me, taking money and losing my soul, just to save your client’s ass sucks. Yes I need something better or else I WILL go to the media and the art world.

COUNT EIGHT: On page 7-8 ‘SKIP’ deleted two paragraphs, which are missing from Cathy Ann Bencivengo’s email to Mr. Steen RE: BET or FOLD to Mr. Steen on Wed April 18th 2001 at 13:39:50.

What’s the deal? I sent my story to your fax # on Monday. If you didn’t get it I don’t know what’s up. It said it went through.

I feel better now that my media friends are behind me. SO, what’s it like defending the sinister side of our situation? You would be angry if you were plagiarized by the widow Seuss. I’ll refax my children’s story from KINKO’s if you email back claiming you never got it.

FACT: Cathy Ann Bencivengo responded: I have not received a fax from you. Please resend it at your earliest convenience to 619-699-2701. Thank you.

IMPORTANT FACT: Cathy Ann Bencivengo emailed Steen vs. Dr. Seuss Enterprises, et al to Steen on Wednesday April 4th 2001 requesting a copy of ‘THE PAINS OF BEING PURE AT HEART’. This entire email is missing from Officer Stephenson’s Declaration In Support of Arrest Warrant.

IMPORTANT FACT: Cathy Ann Bencivengo emailed Steen vs. Dr. Suess Enterprises to Mr. Steen on Monday April 9th 2001. She wrote: I understand from your message you want me to make my request for a copy of your work as “an order of discovery.” My request, however, is not a discovery request. As you know we are contesting personal jurisdiction in this matter and there will be no formal discovery until that question is resolved. My request is simply a request for a professional courtesy. I would very much appreciate, however, if you would forward the story voluntarily at this time. Thank you for your anticipated cooperation. Cathy Ann Bencivengo, Counsel for Dr. Seuss Enterprises and Mrs. Audrey Geisel. This entire email is missing from Officer Stevenson’s Declaration In Support of Arrest Warrant.

IMPORTANT FACT: Cathy Ann Bencivengo contacted Steen first.

IMPORTANT FACT: If personal jurisdiction were the issue, why would DSE have hired Modrall, Sperling, Roehl, Harris and Sisk to represent them in Albuquerque, New Mexico? These facts are missing from Officer Stevenson’s Declaration In Support of Arrest Warrant.

IMPORTANT FACT: Mr. Steen filed his Civil Case 1:01-cv-0211 on FEBRUARY 22nd 2001. In the email from Cathy Ann Bencivengo to Mr. Steen , Subject RE: the HACK Seuss story or the drinks are on her Date:: APRIL 16th 2001 in which Steen requested $2,500,250.50. Steen’s Civil Case 1:01-cv-0211 was not dismissed until JUNE 18th 2003, 796 days after Bencivengo responded to Steen, by Judge Don J. Svet without prejudice. MEANING: Mr. Steen is free to re-file anytime.

IMPORTANT FACT: On December 12, 2001 Mr. Steen re-filed his Civil Case in Portland, OR, the case was dismissed by the honorable Judge Garr M. King without prejudice. The case had actually expired and reached the 120 day limit to go to trial.
MEANING: Mr. Steen is free to re-file at any time.

FACT: On page 9 lines 16-17 of ‘SKIP’s’ Declaration In Support of Arrest Warrant, On Thursday July, 24, 2003 Mr. Steen emailed Karl ZoBell with the subject: Me= Aristophanes & you= Cleon. Mr. Steen wrote: Maybe we can settle out of court and you guys won’t have to live the rest of your lives with the world knowing what type of thieves you are.

FACT: Aristophanes was a comic playwright who wrote a play entitled ‘THE KNIGHTS’ in 424 B.C., which outraged Cleon to the point of prosecution against the playwright. The prosecution was unsuccessful and the play won first place. Mr. Steen was emulating Aristophanes and it is clear from the subject title that time for negotiation was nearing its end. Mr. Steen felt the people of the United States of America had a need to know the truth about DSE and that those involved need to be exposed for the crimes they have committed to the public and the companies in which they work for and the man who gave them everything they have, namely Theodore Seuss Geisel, a.k.a. Dr. Seuss. Mr. Steen gave Mr. ZoBell until Thursday July 31, 2003 to respond with an honorable out of court settlement. Mr. ZoBell never responded. Mr. Steen makes it absolutely clear that the time for an out of court settlement was nearing an end. At that point Mr. Steen felt that it was time to write his play THE TRAGICAL HISTORY OF AUDREY GEISEL or HOW THE GRINCH PLAGARIZED MY GODDAMN CHILDREN’S STORY, which he did between August 4th – 18th 2003. Once the play was written, Mr. Steen immediately started casting roles.

FACT: Much of the emails are missing from Detective Wilton E. Stephenson’s Declaration In Support of Arrest Warrant.

IMPORTANT FACT: On page 12 lines 21-22 of ‘SKIP’s’ Declaration In Support of Arrest Warrant. August 4, 2001, Steen emailed the entire Gray Cary law firm, with an exact parody of a Dr. Seuss painting entitled: BEHIND THE SCENES OF DAISY-HEAD MAYZIE.

FACT: The painting was done out of mockery toward Cathy Ann Bencivengo and DSE because of a ruling by Judge O’Scannlain in a Ninth Circuit case regarding DSE vs. Penguin Books, USA; stating: This decision is significant because it has clarified coherent standard in copyright law for determining whether a potentially infringing work is fair use parody. Mr. Steen made such a parody, therefore, the painting was created under the terms ‘fair use’. Karl ZoBell knows these facts to be true and being that he was former President of the La Jolla Museum of Art should know that attempted larceny (stealing a work of art) is illegal under California law.

FACT: The painting was listed on the search warrant November 5, 2003 5:12 pm. Mr. Steen was arrested at 9:30 am It took the Portland police 8 hours after Mr. Steen was arrested to create the search warrant. The painting is safe. The point being that the painting has nothing to do with the charges of extortion.

NOTE: The entire email regarding the painting is missing from Detective Wilton E. Stephenson’s Declaration In Support of Arrest Warrant page 12, except for the last sentence, which reads: You’re not dealing with a suckah, you’re dealing with an artist.

NOTE: In late July, Mr. Steen phoned Herb Cheyette’s office informing his secretary that he was going forward with his lawsuit and that he needed Hanna Barbara Cartoons address, so as to have them served. His secretary informed Mr. Steen that Mr. Cheyette was an honorable man and that he was willing to make proper negotiations for an out of court settlement (so as not to cause a media scandal). Mr. Steen gave Mr. Cheyette until September 9th, 2003 to respond. Mr. Cheyette never called Steen back. Mr. Steen never expected Mr. Cheyette to call him back.

FACT: On page 9 lines 25-28 & page 10 lines 1-23 of ‘SKIP’s’ Declaration In Support of Arrest Warrant. On Monday, August 18th, 2003 Mr. Steen emailed Jessica Padilla the subject reading: DID YOU KNOW DR. SUESS ENTERPRISES PLAIGARIZED DAISY-HEAD MAYZIE?? READ THIS!!

FACT: The email was clearly written as a means of infuriating Karl ZoBell knowing good and well he no DSE could give Mr. Steen a publishing deal and that they would never admit to having plagiarized Mr. Steen’s children’s story. Once Mr. Steen completed his play the time for negotiations were over. DSE had their chance to settle out of court with Mr. Steen in July of 2001.

COUNT NINE: On August 21, 2003 Mr. Steen emailed Cathy Ann Bencivengo, clearly rubbing all the facts right in her face. NOTE: I am not using this as a means of extortion, because that would be wrong and not nice, no, this new play (is) about using everything everyone has said against them in a court of law.

NOTE: On Page 11 lines 10-27 of ‘SKIP’s’ Declaration In Support of Arrest Warrant, Mr. Steen emailed Karl ZoBell on August 21,2003 with the subject: MY NEW PLAY. The entire contents of the email are pure mockery for their neglect, deceit and lies regarding the out of court settlement in which they never fulfilled their part of the agreement in August, 2001.

COUNT TEN: On page 12 lines 4-13 of ‘SKIP’s’ Declaration In Support of Arrest Warrant. Tuesday, September 9, 2003 Mr. Steen emailed Mr. ZoBell with the subject: I NEED YOUR ADVICE!! BRO?? ‘SUP? The email is pure and utter mockery of Mr. Karl ZoBell. Mr. Steen sent his play to Karl ZoBell.

COUNT ELEVEN: On page 31 lines 1-4 “SKIP” writes: STEEN listed one of his plays as “The Tragic Mellow Death of Doris Dinghy”. By entering Doris Dinghy into Google, I found an Internet article about that play, written by Charles Augustus Steen III and performed in 1999, at Moirae Film and Theatre in Portland, Oregon.

FACT: “The Tragic Mellow Dramatic Death of Doris Dinghy” by Charles Augustus Steen III was performed in 1999 San Francisco Fringe Festival (NOT Portland).

FACT: On November 5, 2003 Mr Steen was arrested by the Portland Police, W.E. “SKIP” Stephenson and Doug Williams from the San Diego C.A.T.C.H. unit.

FACT: In the AMENDED COMPLAINT FELONY FOR EXTRADITION signed by Norma Dormann November 20, 2003.

COUNT 1- WRITTEN THREAT MADE TO EXTORTION: On or about and between APRIL 16th, 2001 and July 24th, 2003 CHARLES AUGUSTUS STEEN III did unlawful with the intent to extort money and property from AUDREY GEISEL, send and deliver to AUDREY GEISEL, a certain letter and writing, which said letter and writing did then and there express and imply and adapted to imply a threat to “””EXPOSE”””, or to impute to him or them any deformity, disgrace or crime in violation of PENAL CODE SECTION 523.

FACT: Mr. Steen filed his civil case 1:01-cv-0211 on FEBRUARY 22nd 2001. Mr. Steen filed his suit Pro Se representing himself. Soon after the defendants were served, Charles Steen was contacted first by Cathy Ann BENCIVENGO of the Gray Cary Law Firm, which represents Dr. Seuss Enterprises. Steen’s request for $2,500,000.00 was a reply to Cathy Ann Bencivengo’s request for offering what he thought would be adequate for an out of court settlement on APRIL 16th , 2001. Mr. Steen’s civil case 1:01-cv-0211 was not dismissed until JUNE 18th 2003, 793 days after BENCIVENGO and STEEN’s email exchange on APRIL 16th , 2001. Steen’s suit never went to trial and was dismissed without prejudice. There had been no judgment made by the Honorable Judge Don J. Svet and the suit may be filed again at any time.

FACT: Mr. Steen never sent Audrey Geissel emails or letters. Mr. Steen has never contacted Audrey Geisel. Steen had been in contact with the Gray Cary law firm regarding his Civil Case 1:01-cv-0211 filed on February 22nd 2001. No attempt has ever made by Charles STEEN to contact Audrey GEISEL personally.

COUNT 2- WRITTEN THREAT MADE TO EXTORTION: On or about and between August 18th 2003 and September 9th 2003 CHARLES AUGUSTUS STEEN III did unlawful with the intent to extort money and property from AUDREY GEISEL, send and deliver to AUDREY GEISEL, a certain letter and writing, which said letter and writing did then and there express and imply and adapted to imply a threat to “””EXPOSE”””, or to impute to him or them any deformity, disgrace or crime in violation of PENAL CODE SECTION 523.

FACT: Mr. Steen never sent Audrey Geisel emails or letters. Mr. Steen has never contacted Audrey Geisel. Steen had been in contact with the Gray Cary law firm regarding his Civil Case 1:01-cv-0211 filed on February 22nd 2001. No attempt has ever been made by Charles STEEN to contact Audrey GEISEL personally.

MOTHER OF ALL FACTS: Mr. Steen did not request any other out of court settlements until August 18th to Jessica Padilla asking her to make a under the table deal so as to get $250.000.00 from the National Endowment for the Arts & that Tim Curry a.k.a.“The Clown” buy the Dr. SEUSS parody painting for the small sum of $50.000.00. Neither of those people are Audrey Geisel. August 18th 2003 is the first day on the second extortion charge. Thus W.E. “SKIP” Stephenson of the San Diego Police Department committed perjury under section 1746 of title 28; because he did alter, distort, make different, modify and change the facts to such a degree as to constitute: “OBSTRUCTION OF JUSTICE” in his very own arrest warrant.

FACT: Mr. Steen was arrested on November 5th, 2003.

LIE: In the PEOPLE OF THE STATE OF CALIFORNIA vs. CHARLES AUGUSTUS STEEN III signed Norma Dormann on page 1, lines 27-28 it states: The defendant has sent various emails to Audrey Geisel who is the widow of Dr. Seuss, a well-known author of children’s literature. The defendant threatened to make public a derogatory play he wrote about the victim unless she paid him large sums of money and made other concessions. Signed Norma Dormann, Investigator dated November 20th, 2003.

FACT: Mr. Steen NEVER sent Audrey Geisel emails or letters. Mr. Steen has never contacted Audrey Geisel. Steen had been in contact with the Gray Cary law firm regarding his Civil Case 1:01-cv-0211 filed on February 22nd 2001. No attempt has ever been made by Charles STEEN to contact Audrey GEISEL personally.

LIE: In the APPLICATION FOR REQUISITION signed by Lorraine E. Rooney, Deputy District Attorney of the County of San Diego dated November 21st 2003, the FACTUAL SUMMARY states that Charles Augustus Steen III has sent various emails to Audrey Geisel.

FACT: Mr. Steen NEVER sent Audrey Geisel emails or letters. Mr. Steen has never contacted Audrey Geisel. Steen had been in contact with the Gray Cary law firm regarding his Civil Case 1:01-cv-0211 filed on February 22nd 2001. No attempt has ever been made by Charles STEEN to contact Audrey GEISEL personally.

IMPORTANT FACT: Mr. Steen refilled his civil case in Portland Oregon on December 12th 2001, Case # 01-CV-1800-KI.

VERY IMPORTANT FACT: The Honorable Garr M. King, wrote on January 22nd 2002: I am able to determine that Steen is alleging a copyright violation against the following defendants: Audrey Geisel, Turner Home Entertainment, Random House, Inc., Dr. Seuss Enterprise, Inc, and Hanna Barbera Cartoons. Steen may proceed against these five defendants only. If he submits summonses and U.S. Marshall Process Return and Receipt Forms (USM- 285), it is ordered that the Clerk shall be made by the United States Marshall’s Office. The action was dismissed without prejudice on June 13th, 2002.

MEANING: Mr. Steen is able to sue Audrey Geisel, Turner Home Entertainment, Random House, Inc., Dr. Seuss Enterprise, Inc, and Hanna Barbera Cartoons; whenever Mr. Steen wishes.

EXHIBITE E i through E vii

HOW J. TONY SERRA, AUDREY GEISEL, RICHARDSERRA, KARL ZOBELL, ERIN O’DONNELL, CHARLES C. EDWARDS & DAVID COPELY, COMMITTED RACKETEERING (THE STATE BAR OF CALIFORNIA INQUIRY NUMBER 05-11183)

EXHIBITN E i

http://www.signonsandiego.com/uniontrib/20050126/news_7m26mca.html
By Robert L. Pincus STAFF WRITER The San Diego Union-Tribune
January 26, 2005. Two gifts of $1 million each have been given to the Museum of Contemporary Art San Diego – one for a major sculpture that's part of the museum's ambitious downtown expansion, the other going toward the MCASD capital campaign. Richard Serra, one of the great contemporary American sculptors, will create a major work for the concourse of the new downtown site, adjacent to the Santa Fe Depot and across the street from the current venue on Kettner Boulevard. Board member Sue K. Edwards and Dr. Charles C. Edwards, longtime supporters of the museum, are giving $1 million toward Serra's commission. Board member and art collector J. Todd Figi of La Jolla is giving $1 million to help fund the expansion and endowment of the downtown facility. Both gifts are part of the museum's 21st Century Campaign. Serra's sculpture, to be unveiled when the enlarged museum opens in fall 2006, will be on the west side of the previously planned Jacobs and Copley buildings. The work will be within an arched walkway to be named the Figi Family Concourse. When completed, the museum's expansion will boost the exhibition space downtown from 6,000 square feet (at American Plaza) to 16,200 square feet. The Edwards’s, who have provided funding for several exhibitions, acquisitions and educational programs for more than a quarter-century, most recently provided the money for the Andy Goldsworthy sculpture in stone, constructed outside the museum's Sherwood Auditorium in La Jolla in 2002. Figi, who joined the museum's board in 2003, is making his largest contribution to date. "The Serra sculpture, being an outdoor work located so close to the tracks where passengers board the trains, will be available to the public anytime, day or night," said museum director Hugh Davies, "and will be a signature work of public art enjoyed by generations to come." The untitled sculpture will contain six forged steel blocks. Each will measure 52 inches by 58 inches by 64 inches and they'll be variously positioned and aligned along the walkway. Serra will bring it to San Diego late next year for installation before the official opening of the new buildings. "To have something on this scale epitomizes what Serra is about and to have an outdoor piece by one of the most important American sculptors is simply great," said MCASD curator Stephanie Hanor. Serra, a native of San Francisco, has residences in New York and Nova Scotia. While in high school he worked in steel mills during the summertime and in his professional life has long emphasized steel as a medium. After studying painting at Yale University, Serra continued to work in steel mills while trying to establish himself as an artist in New York. He first became widely known for his lead sculptures during the late 1960s. In the early '70s, the scale of his work increased and from 1996 to 1999 he created the justly celebrated "Torqued Ellipses" – massive constructions made from large plates of steel which a viewer can enter. Some of those are on permanent display at New York's Dia:Beacon museum.

EXHIBIT E ii

http://www.unabombertrial.com/archive/1998/010898.04.html
Tony Serra: A poor lawyer in dollars only By Ron DeLacy
The Modesto Bee (Published Sept. 19, 1993) A creation of the '60s "I am a creation of the Sixties," says Serra. "The greatest influence on me was the ideology of the Sixties: Anti-materialism, brotherhood, non-racism, love. Those are things I still believe in." He and his ex-wife gave their children Flower Child names: Shelter, Ivory, Chime, Wonder and Lilac. Serra doesn't expect his children to be his clones, of course, and wouldn't want them to be. He is not one to wring his hands over the Generation Gap or what child psychologists have to write about the importance of understanding children. "Your kids should start on your horizon," Serra says. "They should pick up where you left off. If you understand your kid, the species isn't advancing." His kids are between 14 and 20 now, and they have advanced to high schools and colleges. Dad says they are not consumers, and that they all get good grades, which is just about the extent of what he asks of them. Serra says one of his brothers, the world-famous sculptor, Richard Serra, is putting them through college. To Tony Serra, college is important, money isn't, and tuition is pretty expensive, after all, not to mention room and board. It all adds up to a lot more bread than Tony Serra, no matter how many Saturdays he works or how much overtime he puts in, will ever hope to make.



EXHIBIT E iii

http://specialevents.com/mag/meetings_french_twist/
SPECIAL EVENTS MAGAZINE: French Twist by Lisa Hurley May 1, 1999 12:00 PM The Museum of Contemporary Art, San Diego, has relied on a "Monte Carlo" fund-raising benefit-complete with casino-style gambling-every year since 1976. The formula has proved a winner, netting a total of $2.75 million since its inception. The theme for the most recent event-"A Celestial Night in Monte Carlo"-came from “honorary chairwoman Audrey Geisel”, widow of "Dr. Seuss" writer Ted Geisel. To carry it out, Newport Beach, Calif.-based Masterpiece Productions turned to contemporary French design to create a sleek, sophisticated nightclub with a heavenly ambience.

EXHIBIT E iv

http://www.mcasd.org/support/sponsors.asp
THANKS TO OUR DONORS!: It is through the generous support of MCASD's Members and donors that many thousands of San Diegans and visitors alike enjoy our world-class Museum in La Jolla as well as our outstanding facility downtown. At the $1,250 level and above, current donors are listed quarterly for the period of one year.
$100,000 or more David C. Copley, Helen K. Copley, James S. Copley Foundation. $50,000 - $99,999 Sue K. and Charles C. Edwards $25,000 - $49,999 Audrey Geisel/Dr. Seuss Foundation, $10,000 - $24,999 Karl and Barbara ZoBell, $5,000 - $9,999 Copley Newspaper

EXHIBIT E v

http://www.sdnewsnotes.com/ed/notes/0503note.htm
Dinner chairmen include Manpower CEO Mel Katz and his wife, Linda; former Scripps Clinic and Research Institute president and FDA commissioner Dr. Charles C. Edwards and his wife, Sue; and Dori Kaufman, owner of Bread & Cie Bakery & Café. Honorary committee members include Qualcomm CEO Irwin Jacobs and his wife, Joan; "Dr. Seuss" widow Audrey Geisel; and La Jolla Playhouse board chair Joel Holliday and his wife, Rosanne.

EXHIBIT E vi

http://www.signonsandiego.com/news/metro/20040821-9999-1m21seuss.html
By Onell R. Soto UNION-TRIBUNE STAFF WRITER , August 21, 2004
An Oregon playwright who pleaded guilty to trying to extort $2.5 million from the widow of Theodor "Dr. Seuss" Geisel was quietly sentenced to probation and anger-management classes four months ago. Charles Augustus Steen III, 33, of Portland, was sentenced in San Diego Superior Court April 30 to four years' probation, said a spokesman for the District Attorney's Office. Steen pleaded guilty as part of a plea agreement in which prosecutors dropped a second extortion charge. If he stays out of trouble for 18 months, he can have the felony reduced to a misdemeanor, his lawyer said. Everyone involved agreed not to publicize the case.
(EXCEPT for “THE PLAINTIFF” who wanted the media and who had no idea they were all protecting each other’s personal interest.)

He pleaded guilty on the 100th anniversary of Geisel's birth, said lawyer Cathy Bencivengo, who represents Dr. Seuss Enterprises. "We did not in any way want to overshadow that positive event." Steen never meant to harm Audrey Geisel, his lawyer said, but was frustrated because he believes the Dr. Seuss estate plagiarized a play he wrote, publishing it in 1995. Audrey Geisel, 83, said she found the unfinished manuscript for "Daisy-Head Mayzie" in a drawer at the La Jolla home she shared with her husband until his death in 1991. Steen copyrighted his play (it’s a children’s story), "The Pains of Being Pure at Heart," in 1991, and said he wrote it in 1990, according to the U.S. Copyright Office. Bencivengo said the manuscript for "Daisy-Head Mayzie" was written in the 1960s, before Steen was born. "They're both written in a rhyming meter, but so what? They're very dissimilar," she said. "It's not a children's story by a long shot." Steen sued the estate, acting as his own lawyer, but a New Mexico judge dismissed the case. Steen then wrote another play, "The Tragical History of Audrey Geisel or How the Grinch Plagiarized My . . . Children's Story," and made a painting of Dr. Seuss characters in sexual situations. "It was his way of expressing his anger," O'Donnell said. "He's an artist." Steen wrote e-mails to Bencivengo, threatening to produce the play and publicize the painting if he didn't get money or help in publishing his own works. Bencivengo called the play and painting "obscene and distasteful" but didn't do anything for about a year when Steen stopped writing. After Steen wrote again and asked for $2.5 million "or I'll do something you'll regret," the lawyer felt she had to contact police. "It rose to a point where we were concerned about people's physical safety," Bencivengo said yesterday. Members of the San Diego Computer and Technology Crime High-Tech Response Team worked with Portland police, who arrested Steen. Onell Soto: (619) 293-1280; onell.soto@uniontrib.com

EXHIBIT E vii

http://www.sdreader.com/php/cover.php?mode=article&showpg=1&id=2002112
A Slap in the Face of the Past By Matt Potter 1 As reported by U-T society writer Burl Stiff, the Copley party, heralding the opening of a Christo exhibit at the museum's Prospect Street headquarters gallery, featured such museum stalwarts and Copley chums as Copley Press attorney Karl ZoBell; Mavourneen O'Connor, twin sister of former San Diego mayor Maureen O'Connor; and former TV reporter Susan Farrell. Museum director Hugh Davies was there, along with Bersin in-law Foster, the museum's president and widow of Stanley Foster, a well-connected real estate developer and local financier. Wrote Stiff: "Copley is a major collector of Christo drawings and the principal underwriter of an exhibition -- 'Christo and Jeanne-Claude in the Vogel Collection' and 'Christo in the David C. Copley Collection.' "


EXHIBIT E viii

http://www.dlapiper.com/us/people/biodetail.aspx?id=11350
Karl ZoBell's practice emphasizes intellectual property protection and exploitation, licensing and marketing, corporate governance, trusts and estates, related tax issues,
real estate transactions and land use matters. Karl advises Dr. Seuss Enterprises, L.P. on all business matters, including character licensing and exploitation and marketing of Dr. Seuss books and characters. Karl also provides strategic planning for, negotiation and documentation of intellectual property agreements for books, motion pictures, merchandise, television, live action productions, and related matters. Mr. ZoBell serves as a Director for Copley Press, Inc.


EXHIBIT E ix

http://www.cjr.org/tools/owners/copley.asp
WHO OWNS WHAT, Copley Press Inc. Daily Newspapers
California, The San Diego Union-Tribune, The Daily Breeze (Torrance), Palos Verdes Peninsula News (Palos Verdes)

EXBIHIT F i & F ii

HOW HERB CHEYETTE & STEVEN PAUL LEVIA COMMITTED COUNTERFEITING AND FORGERY OF FICTITIOUS OBLIGATIONS 18 U.S.C. 514 (a)(1)(2) regarding the lost work of Dr. Seuss in order to stop me from my limitations on actions 17 U.S.C. 507 (a)(b) being that DSE committed an offense under 17 U.S.C. 506 (d)(1)(A). EXCUSATIO NON PETITA ACCUSATIO MANIFESTA.

These two letters were sent via FAX from ICM to Stacy Ison at Willamette Week, Portland, Oregon February 7th 2002.

EXHIBIT F i

January 24th, 1991. Mr. Herb Cheyette ICM 40 West 57th Street New York, New York 10019 RE: DAISY-HEAD MAZIE. Dear Heb; As per our conversation of the other day I’m enclosing a copy of the above mentioned story by Dr. Seuss. We found this in our files. It seems that Ted submitted to Chuck many a moon ago. I find it quite charming, and as we are looking at potential projects for prime time TV half hour specials we would like to know if Ted would be interested in optioning to us the rights. It is just a query at the moment. We need to do some further discussions with a third party to see if we will be in a position to make an offer. In any case, if Ted has forgotten about and/or lost his copy of DAISY HEAD MAZIE, we are glad to have able to recover the work. Best regards, Steven Paul Leiva, President.


EXHIBIT F ii

January 30th, 1991 Mr. Steven Paul Leiva President Chuck Jones Productions 1420 Ventura Boulevard Suite C 481 Sherman Oaks, CA 91423 Re: DAISY-HEAD MAYZIE Dear Steve: Thanks so much for your letter of January 24th , with enclosures. I have discussed “Daisy-Head Mayzie” with Ted, who informs me that he is currently considering other uses for the story. Please thank Chuck for his interest. Sincerely, Herb Cheyette.

EXHIBIT G

HOW CATHY ANN BENCIVENGO DID KNOWINGLY AND WILLFULLY COMMIT PERJURY 28 U.S.C. 1746

On APRIL 9th 2001 in the e-mail from Cathy Ann BENCIVENGO to Charles STEEN, the Defendant; Subject: Steen v. Seuss, she wrote:

My request is simply a request for a professional courtesy.

As you know, I requested a copy from the Copyright Office, but have not received it.

LIE: The request for “The Pains of Being Pure at Heart” from the Library of Congress was not placed until April 28th 2001, by Cathy Ann Bencivengo.

EXHIBIT H

HOW ERIN O’DONNELL DID KNOWINGLY AND WILLFULLY ASSIST IN THE COVER UP OF DAISY-HEAD MAYZIE FOR MISPRISION OF FELONY 18 U.S.C. 4 & RELATING TO OBSTRUCTION OF CRIMINAL INVESTIGATION 18 U.S.C. 1510 (3)(A).

On March 3rd Mr. Richard Sharp of the Library of Congress sent a FAX to Erin O’Donnell. He wrote:

I have been speaking with your client Charles Steen regard an alleged infringed work of his titled ‘The Pains of Being Pure at Heart’. His mother paid for an uncertified copy of his work, however, now Charles wants a report sent to you. As you might guess, nothing is free.

If you would like a search report done it would cost $80. You can call 202.707.6787 and pay for it with a credit card. You would request a “search of authorization and inspection files.”

If you’d rather mail your order to us overnight delivery call me at 202.707.6789 for the address or if you have any other questions.

Sincerely, Richard Sharp

Mrs. Erin O’Donnell did not respond to Mr. Richard Sharp. She did nothing for her client (the Plaintive).

EXHIBIT I

HOW LAKE PERRIGUEY OF BRADLEY J. WOODWORTH AND ASSOCIATES, PC, DID WILLFULLY AND KNOWINGLY ASSIST IN THE COVER UP OF DAISY-HEAD MAYZIE FOR MISPRISION OF FELONY 18 U.S.C. 4 & RELATING TO OBSTRUCTION OF CRIMINAL INVESTIGATION 18 U.S.C. 1510 (3)(A).

“While it may indeed be provable that Janet Shulman had access to your story submitted long ago, and even if it were provable that the execs (at) DSE created a story that was inspired by your work, it is not at all evident to me that Daisy-Head Mazey (Mayzie) is a derivative work of substantial similarity.”

“I did contact Janet Schulman, who put me in touch with the agent Herb Cheyette who told me to contact Zobell. I did not make contact with Zobell.” STAEMENTS OF LAKE PERRIGUEY, OREGON STATE BAR INQUIRY NUMBER 403617.

EXHIBIT J

HOW JOSEPH ROSE OF THE OREGONIAN DID SO KNOWLINGLY AND
WILLFULLY COMIT ACTUAL MALICE REGARDING LIBEL DEFAMATION OF CHARCTER 28 U.S.C. 2680 (h).

The Front Page of the Oregonian, August 19th 2004, ‘Oh, the sentence he will serve’ by Joseph Rose.

Somewhere in Con-ville, Charles Steen hatched his plot. He wanted money and he wanted a lot. To the widow of Dr. Seuss, the Portland man e-mailed a threat, “Give me 2.5 million, or I’ll do something you’ll regret.”

It was extortion! A Grinch-like pinch, you know. This Steen man, this mean man, threatened to put on a show.


FACT: Mr. Steen NEVER wrote, ”Give me 2,5 million or I’ll do something you’ll regret.”






INFORMATION FROM THE LIBRARY OF CONGRESS

STEEN
Registration Number:

TXu-500-969
Title:

The pains of being pure at heart. Story and drawings by acCharles Augustus Steen 3rd, 1971-.
Note:

Children's story.
Claimant:

Charles Augustus Steen III
Created:

1990

Registered:

21Jun91

Miscellaneous:

C.O. corres.
Special Codes:

1/B///A

Registration Number:

TXu-1-179-051
Title:

The tragical history of Audrey Geisel.
Description:

1 v.
Claimant:

acCharles Augustus Steen 3rd, 1971-
Created:

2004

Registered:

17May04

Title on © Application:

How the Grinch plagiarized my goddamn children's story.
Previous Related Version:

Appl. States The pains of being pure at heart, TXu 500-969 is preexisting material.
Special Codes:

1/B/D

SEUSS
Registration Number:

PA-700-090
Title:

Daisy-Head Mayzie: no. H00610-94001 / directed by Tony Collingwood.
Description:

Videocassette ; 3/4 in.
Note:

Animation.
Claimant:

acHanna-Barbera Cartoons, Inc., and acDr. Seuss Enterprises, LP (employers for hire)
Created:

1994

Published:

5Feb95

Registered:

1May95

Previous Related Version:

Character, story, lyrics by Theodor Geisel preexisting.
Claim Limit:

NEW MATTER: all cinematographic material incl. teleplay & music.
Special Codes:

4/X/L

Registration Number:

TX-4-042-306
Title:

Daisy-Head Mayzie / by Dr. Seuss.
Imprint:

New York: Random House, c1994.
Description:

1 v.
Claimant:

Dr. Seuss Enterprises, LP
Created:

1991

Published:

30Dec94

Registered:

10Apr95

Author on © Application:

Theodor S. Geisel , -1991 p.k.a. Dr. Seuss.
Claim Limit:

NEW MATTER: additions & artwork.
Special Codes:

1/B/D


LIST OF PLAGIARIZED COMPARISONS
Both Lukus Loo & Mayzie McGrew grow seven petal flowers from their heads.
Txu-500-969 pg 26, TX-4-042-306 pg 3.

Both Lukus Loo & Mayzie McGrew are reading books in the beginning.
Txu-500-969 pg 2, TX-4-042-306 pg 2.

Both Lukus Loo & Mayzie McGrew are singled out and taunted by classmates.
Txu-500-969 pg 8, TX-4-042-306 pg 7.

Both Lukus Loo & Mayzie McGrew have an animal friend that appears in text and illustrations. Txu-500-969 pg 1-34, Tx-4-042-306 pg 1-44.

Both Lukus Loo & Mayzie McGrew in the beginning are not famous.
Txu-500-969 pg 1, TX-4-042-306 pg 2.

Both Lukus Loo & Mayzie McGrew have celebrations in their honor.
Txu-500-969 pg 19, TX-4-042-306 pg 35.

Both Lukus Loo & Mayzie McGrew gain fame and wealth.
Txu-500-969 pg 20, TX-4-042-306 pg 2.

Both Lukus Loo & Mayzie McGrew go to the wisest man in town for advice.
Txu-500-969 pg 9-10, TX-4-042-306 pg 8.

Both Lukus Loo & Mayzie McGrew are changed drastically by the flowers on their head. Txu-500-969 pg 26-33, TX-4-042-306 pg 6-46.

Both Lukus Loo & Mayzie McGrew at one point care more about fame and wealth than love. Txu-500-969 pg 21, TX-4-042-306 pg 34.

Both Lukus Loo & Mayzie McGrew throw their money on the ground.
Txu-500-969 pg 25, TX-4-042-306 pg 38.

Both Lukus Loo & Mayzie McGrew feel the need to leave town.
Txu-500-969 pg 27, TX-4-042-306 pg 38.

Both Lukus Loo & Mayzie McGrew are enlightened by the flower(s).
Txu-500-969 pg 25, TX-4-042-306 pg 46.

Both stories have others with FAKE flowers on their heads, emulating Lukus Loo & Mayzie McGrew Txu-500-969 pg 35-36, TX-4-042-306 pg 36-37.



EXAMPLE OF PLAGIARIZED TEXTUAL EXPRESSION

NOTE: Near the end of ‘The Pains of Being Pure at Heart’ it read: And these are the words that he read. Txu-500-969 pg 35.

NOTE: Near the end of ‘Daisy-Head Mayzie’ it reads: And these are the words that poor Mayzie said. TX-4-042-306 pg 39.

STATEMENTS FROM AUDREY GEISEL & KARL ZOBELL
Neither I, nor my lawyers, nor my husband’s publisher, could see any resemblance in the art, plot, or language.
Dated: 4-22-04 Audrey S. Geisel

Mr. Steen sent us an email copy of his book. The art was bad and the text was worse. It had no recognizable similarity to the Dr. Seuss Book in question. Further, we, and Mr. Geisel’s agent, had clear proof that the Dr. Seuss book in question had been put to paper by him years before the Steen work was put together by him.
Dated: 4-22-04 Karl ZoBell






REQUEST FOR RELIEF
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff is three times the amount requested as an out of court settlement on APRIL 16, 2001. from DSE for the sum of $2,500,252.50 for breach of settlement being a total of $7,500,701.50 under 18 U.S.C. 1964 (c ).
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from DSE for FRAUDULENT COPYRIGHT NOTICE 17 U.S.C. 506 (c), CRIMINAL INFRINGMENT 18 U.S.C. 2319; of the “Daisy-Head Mayzie” book published by Random House and Dr. Seuss Enterprises would be at the low end $750.00 per infringement and being that over 500.000 copies of Daisy-Head Mayzie were sold the total remedies would be $375,000,000.00. Being that it was a joint partnership, DSE and Random House owe the Plaintiff 187,500,000.00.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff for FRAUDULENT COPYRIGHT NOTICE 17 U.S.C. 506 (c), CRIMINAL INFRINGMENT 18 U.S.C. 2319; of the ‘Daisy-Head Mayzie’ video published by Collingwood O’Hare Entertainment Ltd would be at the low end $750.00 per infringement and being that over 10.000 copies were sold the total remedies being 7,500,000.00.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from J. Tony Serra and Erin O’Donnell, regarding attorney’s fees and cost 31 U.S.C. 3730 (d) for neglect and breach of contract is three times the amount compensatory damages $11,000.00. being $33,000.00. Mr. J. Tony Serra are Erin O’Donnell, being that they both deceived the Honorable Judge Joseph Maguire and myself, are entitled to each pay half of $33,000.00 being $16,500.00 under 18 U.S.C. 1964 (c ).
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties; regarding the racketeering and unlawful monetary transactions 18 U.S.C. 1975, 18 U.S.C. 1962 (a); conflicts if interest 41 U.S.C. 423 (b) being that Richard SERRA, the brother of J. Tony SERRA, received from Charles C. Edwards for the sum of $1,000,000.00 for a statue which was placed at the Museum of Contemporary Arts in San Diego in front of the David C. Copley Building in which Audrey Geisel is the “chair woman”; the Plaintiff is entitled $50,000.00 from Charles C. Edwards, $50,000.00 from Audrey Geisel, $50,000 from Richard Serra and $50,000.00 from Karl ZoBell plus twice the amount received from Richard SERRA of $1,000,000.00 being $2,000,000.00.
Being that David C. Copley donated $100,000.00, Charles C. Edwards donated 50,000.00, Audrey Geisel donated 25,000.00 and Karl ZoBell donated 10,000.00 to MCASD for Richard Serra’s statue under 41 U.S.C. 423 (e)(2) the Plaintiff is entitled relief of $46,250.00 from each: Copley, Edwards, Geisel and ZoBell being a total of $185,000.00 for 18 U.S.C. 1957, 18 U.S.C. 0152.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) the Plaintiff is entitled $100,000.00 from Janet Schulman of Random House, $100,000.00 from Tim Curry, $100,000.00 from Herb Cheyette, $100,000.00 from Steven Paul Levai, $100,000.00 from Cathy Ann Bencivengo, $100,000.00 from J. Tony Serra, $100,000.00 from Erin O’Donnell, $100,000.00 from Richard Serra, $100,000,00 from W.E. “SKIP” Stephenson, $100,000.00 from Charles C. Edwards and $100,000.00 from David Copely for with respect to conspiracy against civil rights 18 U.S.C. 0241, fraud and false statements 18 U.S.C. 1OO1, 26 U.S.C. 7206, obstruction of Justice 18 U.S.C. 1512, perjury 18 U.S.C. 1621, 28 U.S.C. 1746, misprision of felony 18 U.S.C. 0004, bribery 18 U.S.C. 0152, 18 U.S.C. 201 and racketeering 18 U.S.C. 1957.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) the Plaintiff is entitled $1,497,000.00 from the San Diego Police Department and or San Diego Chief of Police William M. Lansdowne for $1,000.00 per day for wrongful probation for 18 months at total of 447 days, 10,000.00 per day for wrongful obligation of 200 hours of community service a total of 25 days and $100,000.00 for wrongful imprisonment being a total of 8 days .
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from Lake Perriguey for 18 U.S.C. 4 & 18 U.S.C. 1510 (3)(A) being the sum of no less than $75,000.00.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from The Institute of Children’s Literature for 18 U.S.C. 1951-1968 is to be no less than $75,000.00
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from Pier 5 Law Offices for 18 U.S.C. 1951-1968 is to be no less than $75,000.00.
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from Random House for 18 U.S.C. 1951-1968, 17 U.S.C. 506 (c ) and 18 U.S.C. 2319 is to be no less than $75,000.00
Under 42 U.S.C. 1320a-7a (4)(B)(7)(A)(B) of Civil Monetary Penalties the amount owed to the Plaintiff from Joseph Rose of the Oregonian for 28 U.S.C. 2680 (h) is no less than $75,000.00 of 28 U.S.C. 1331 and or a written apology on the front page of the Sunday Oregonian detailing the facts of this case.
Under 42 U.S.C. 3614 (d) (I) (c) of Civil Monetary Penalties the amount owed the Plaintiff from each Defendant is to be $20,803,984,29 of the Clayton Act 7A (B) of 15 U.S.C. 41 (j)(K) not in excess of $200.000.000 for their combined concealment of facts for each having acted in the cause of Audrey Geisel’s reputation, a total of $395,275,701.50. Under 42 U.S.C. 3614 (d) (I) (c) of Civil Monetary Penalties the amount owed the Plaintiff from Audrey Geisel for 18 U.S.C. 1964 (c ) for probation fines of $40.00 a month for 18 months being a total of no less than $2,160.00.
Under 17 U.S.C. 501 (b) The legal owner of an exclusive right under a copyright is entitled to institute an action for any infringement of that particular right committed while he or she is the owner of it. Under 28 U.S.C. 2501 the statute of limitations to sue the Defendants expires November 5th 2009, under 18 U.S.C. 1964(c), 18 U.S.C. 241 and 28 U.S.C. 2501 of 17 U.S.C. 501 (b), for 17 U.S.C. 504 (a)(b)(c)(1)(2), 17 U.S.C. 503 (a)(b), 17U.S.C. 506 (a)(1)(2)(b)(c)(d)(e) (f), 17 U.S.C. (a)(b), 17 U.S.C. 505, 17 U.S.C. (1)(2)(3)(4)(5).
Being that EVERYTHING herein revolves around Civil Case 1:01-cv-0211 which started IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO it is obvious as to why it should be resolved IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO.

Simplified Breakdown of Relief
(if each individual were to be sued without having worked together)

INDIVIDUALS & COMPANIES AMOUNT
J. Tony Serra $116,500.00
Erin O’Donnell $116,500.00
Audrey Geisel & Dr. Seuss Enterprises $195,099,111.50
Random House $187,575,000.00
Collingwood O’Hare Entertainment Ltd $7,500,000.00
Charles C. Edwards $96,250.00
Richard Serra $2,050,000.00
Karl ZoBell $281,250.00
David C. Copley $146,250.00
Herb Cheyette $100,000.00
Janet Schulman $100,000.00
Steven Paul Levai $100,000.00
Cathy Ann Bencivengo $100,000.00
W. E. “SKIP” Stephenson $100,000.00
San Diego Chief of Police William M. Lansdowne $1,497,000.00
The Institue of Children’s Literature $75,000.00
Pier 5 Law Offices $75,000.00

Lake Perriguey $75,000.00

Joseph Rose $75,000.00

(Being that each individual worked together the remedy is split equal under 15 U.S.C. 41 j,k. of the Clayton Act 7A (B), being $20,803,984.29 for each Defendant under 42 U.S.C 1988 TOTAL: $395,277,861.50 of 42 U.S.C. 1983 for 18 U.S.C. 241 and 28 U.S.C. 2501 of 17 U.S.C. 501 (b), for 17 U.S.C. 504 (a)(b)(c)(1)(2), 17 U.S.C. 503 (a)(b), 17U.S.C. 506 (a)(1)(2)(b)(c)(d)(e) (f), 17 U.S.C. (a)(b), 17 U.S.C. 505, 17 U.S.C. (1)(2)(3)(4)(5).)






CONTACTS FOR THE DEFENDANTS


J. Tony Serra # 23639
Pier 5 Law Offices
506 Broadway
San Francisco, CA 94133
415.986.5591

Audrey Geisel & Karl ZoBell # 29401
1200 Prospect St, Suit 575
La Jolla, CA 92037-3654
858.638.6800

Cathy Ann Bencivengo # 138791
United States District Court
940 Front Street
San Diego, CA 92101
619.557.7688

Erin Michelle O’Donnell # 210530
1260 B Street, Suit 220
Hayward, CA 94541
510.808.4109

Janet Schulman
Random House
1745 Broadway 3rd Floor
New York, NY 10019

The Institute of Children’s Literature
93 Long Ridge Road
West Redding, CT 06896
203.792.8600

C. Judith Brunstad
14 Shields Lane
Ridgefield, CT 06877

Mr. Herb Cheyette
ICM 40 West 57th Street
New York, New York 10019
212.556.5600

Mr. Steven Paul Leiva
Chuck Jones Productions
1420 Ventura Boulevard Suite C 481
Sherman Oaks, CA 91423

Tim Curry - care of
Hyler Management
25 Sea Colony Dr.
Santa Monica, CA 90405
310.396.7811



Richard Serra
Studio 360/WNYC
One Center Street Floor 30
New York, NY 10007
212.669.3712

Charles C. Edwards –care of
Mandeville Special Collections Library
The University of California San Diego
Geisel Library
9500 Gilman Drive
La Jolla, CA 92093-0175
858.534.2533

David C. Copley
350 Camino de la Reina
San Diego, CA 92108
619.299.3131

W.E. “SKIP” Stephenson
330 W. Broadway, Suite 750
San Diego, CA 92101
619.531.3660

Lake James H. Perriguey
Law Works, LLC
507 NW 22nd Ave # 105
Portland, OR 97210-3285
505.803.5184

Joseph Rose – care of
The Oregonian
1320 S.W. Broadway
Portland, OR 97201
503.221.8150

Chief William M. Lansdowne
1401 Broadway
San Diego, CA 92101
619.531.2000

Collingwood O’Hare
Entertainment Ltd
10-14 Crown Street
London, England
W38SB
+44 20 8993 3666


STATEMENT OF CHARLES AUGUSTUS STEEN III

My name is Charles Augustus Steen III; I am a playwright.

I was falsely accused of extortion by Audrey Geisel and her attorney Karl ZoBell; who was once impeached by the City Counsel of San Diego. I took the advice of my former attorney J. Tony Serra and foolishly plead guilty. My record has since been expunged.

Soon after the death of Theodore Seuss Geisel in 1991 Audrey created Dr. Seuss Enterprises known as DSE. During Theodore Seuss Geisel’s lifetime he detested the idea of his creations to be marketed. Since his death DSE has licensed over 5,000 products. It is DSE whom have exploited the good name of Dr. Seuss with such atrocities as the movies ‘How the Grinch Stole Christmas’ and the even worse ‘The Cat in the Hat’ which has been described as unbearable and an insult to Dr. Seuss. Since the death of Theodore Seuss Geisel six books have been posthumously created by such unscrupulous authors as Tim Curry, Lane Smith and Jack Prelutski.

I have clear proof that my children’s story ‘The Pains of Being Pure at Heart’ was created before the fake Dr. Seuss book ‘Daisy-Head Mayzie’. I also have clear proof how it was plagiarized and all the individuals involved in the cover up of such a heinous crime,

It is obvious that irrational behavior of both Audrey Geisel and her attorney Karl ZoBell and the corrupt nature of J. Tony Serra whose brother Richard Serra received a one million dollar quid pro quo payoff by Audrey’s friend Charles C. Edwards is obvious as to why J. Tony Serra to convinced me in pleading guilty. Being that J. Tony Serra is affiliated with such organizations as the Hells Angels; I feel that my safety is threatened.

This case is not about the money; this case is about the TRUTH. It is only fair that each defendant take a polygraph.

I fully admit that that my naivety of the law in regards to my original civil case allowed these individuals to treat me in such a manor. But that old saying, “That which does not kill you makes you stronger.” holds true in this case.

While on probation I successfully directed and produced two plays of mine; ELYSIUM and THEM AND THE VIRTUOUS MAN.

The information in my evidence has been forwarded the FBI in Portland Oregon.

Dated: __________________
____________________________
Charles Augustus Steen III