Dubin Law Offices Amazing Response to Nationwide Title Clearing's "Signers" Attorney re: Bly, Moore, and Doko Videotaped Depositions

55 Merchant Street, Suite 3100 Harbor Court, Honolulu, Hawaii 96813 Honolulu (808) 537-2300 Facsimile (808) 523-7733 San Francisco (415) 659-9855 Los Angeles (213) 947-6262 San Diego (619) 677-6200 Toll Free: (888) dubinlaw Writer's E-Mail: gdubin@dubinlaw.net www.dubinlaw.net ATTORNEYS LICENSED IN HAWAII, CALIFORNIA AND NEVADA

August 27,2016 Chris A. Barker, Esq. Barker & Cook 501 East Kennedy Blvd., Suite 790 Tampa, Florida 33602 Re: Bly, Moore, and Doko Dear Mr. Barker: I am in receipt of your letter dated July 29,2016, expressing your concern with regard to my posting of video depositions of the above-referenced individuals on my Foreclosure Hour Website, upon receipt of which I gave your inquiry to independent counsel for review. As you know, those videos were posted on my website in conjunction with my radio show, for which I claim a media freedom of the press First Amendment privilege, further rendering my sources confidential under the reporters' shield law. Thank you nevertheless for bringing to my attention Circuit Judge Haworth's earlier Order, for I of course recognize the importance of adhering strictly to all relevant court orders no matter which jurisdiction they may issue from. However, I have been advised that Circuit Judge Haworth's Order does not apply to me for the following reasons: 1. I did not secure the videos from a source listed in his restraining order, as the only individuals covered by the Order are the enjoined disseminators. You are surely familiar with the decision of the United States Supreme Court in the Pentagon Papers case. 2. I was furthermore not a part of the referenced Florida litigation, nor do I reside or have I ever resided in Florida, as a result of which Circuit Judge Haworth had no jurisdiction over me at the time that Order was issued nor presently. 3. As you know, sometimes it is not easy to identify in one's legal research judicial statements supporting the obvious, but even had I secured the videos from an enjoined disseminator and even had the Court had personal jurisdiction over me to enforce the Order, neither of which is however true, research nonetheless does occasionally support the obvious, that when a case is dismissed, as was yours many years ago before Circuit Judge Haworth, and voluntarily with prejudice I am advised, the Court lost jurisdiction of the case and "the effect of the filing of a notice of dismissal . . . is to leave the parties as though no action had been brought," Janssen v. Harris,321 F.3d 998 (1Oth Cir.2003). Finally, Ms. Moore in particular, for instance, has even very recently cost several of my clients their real property as the result of not only her dishonest robo-signing under oath, but in one instance due to her belated declaration, deliberately dishonestly filed in Court in reply papers in Hawaii in the Third Circuit Court in Kona, that resulted in an unfair $825,000 deficiency judgment, at a time that I understand contrary to her Declaration testimony in that relatively recent case she did not even any longer work for that company, which was filled with other false statements under oath in that same case. That affected client of mine in particular has continually asked me to sue Ms. Moore for fraud on the Court in Hawaii, so it would seem that if you persist in continuing to threaten me and interfering with my website, getting my attention you may be doing your clients a great disservice. If, for instance, your threats and interference were to continue, please expect a countersuit against your clients to be forthcoming in Hawaii, including perhaps in the form of a class action, long overdue, especially since your clients' false filings are still to this day flooding foreclosure courts, including in Hawaii, which incidentally makes their videos not only still timely, but their viewing, especially in court proceedings, one, in the public interest, two, their submission in court as material evidence fully protected, and three, privileged in the exercise of freedom of the press. Very truly yours, Gary Victor Dubin GVD/o

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