Notice and Demand of Proof of Claim

7/22/2019 Notice and Demand of Proof of Claim

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July 30, 2014

Delivery Confirmation: Certified Mail Tracking Number 7013 1090 0000 7463 0304

VERFIED NOTICE AND DEMAND TO VALIDATE CLAIM

From Affiant:

Sis. Tauheedah S. Najee-Ullah ElAddress redacted for posting to social media

To Respondents:

G.S. Victor Taylor El and

Cynthia Smith Bey, Secretary

c/o 8701 S. Normandie Ave.

Los Angeles, CA 90044

Re: Claim to Operating and Other Rights over Califa Media and its Products.

NOTICE TO PRINCIPAL IS NOTICE TO AGENT

NOTICE TO AGENT IS NOTICE TO PRINCIPAL

APPLICABLE TO ALL SUCCESSORS AND ASSIGNS

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SILENCE IS AQUIESCENCE

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TAKE NOTICE

Respondent(s) failure in providing Affiant pursuant to Acts 3 and 4 of the Divine

Constitution & Bylaws of the Moorish Science Temple of America with the requisite

rebuttal and proof thereof signifies that Respondent(s):

1. Has no lawful, bona fide, verified claim in the above referenced matter;2. Waives any and all claims against Affiant;3. Tacitly agrees that Respondent(s) will compensate Affiant for all costs, fees, and expenses

incurred in defending against any arising civil matters due to continued attempts to press

issues in the un-rebutted affidavit.

This notice and affidavit constitutes my efforts to resolve this ongoing claim as detailed below

Done this 30thDay of June, 2014.

/s/ Sis. Tauheedah S. Najee-Ullah El_________________

Sis. Tauheedah S. Najee-Ullah El

Address redacted for posting of public notice to Scribd.com


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Instructions

Pursuant to common and international law, respondent has 30 days from receipt of this affidavit to

rebut in kind and fashion delivered unto him; specifically a notarized affidavit of rebuttal sent via a

third party with proof of service.

All items are categorized according to topic (A, B, C etc) and fact to rebutted (1, 2, 3, etc.) Rebuttals,

if any, are to be entered onto a separate document referencing said categories. Denials rebuttedwithout accompanying explanation and proof will be deemed admitted until such is provided.

Respondents are hereby barred from further claims of Califa Media in any venue, unless they be

Dirty Moors about the business of spreading untruths they cannot prove. Allah is the best witness

between un Sura 6:19

Statement of Facts for:

___________________A. Califa Media

1. Fact: Califa Media is a not-for-profit unincorporated association of self-published authors.

Admit/ Without Knowledge/ Deny

2. Fact: Sis. Tauheedah S. Najee-Ullah El originated the trademark name Califa Media.


3. Fact: On March 23, 2014, Najee-Ullah El informed Taylor El via text that Califa Media would be

an entity with her as agent set up outside the Moorish Science Temple 101 California due to the

previously mentioned procrastination. See email dated March 23, 2014 appended hereto as Exhibit

A.Admit/ Without Knowledge/ Deny

4. Fact: The Moorish Science Temple 101 California had not officially opened at the sending of the

March 23, 2014 message. Id


5. Fact: On March 25, 2014 an EIN was requested by Najee-Ullah El for MOORISH SCIENCE

TEMPLE CALIFORNIA to enable Califa Media banking. See redacted copy of EIN Confirmation for

MOORISH SCIENCE TEMPLE CALIFORNIA, operating in the State of California enjoying

protections afforded all religious organizations.


6. Fact: On March 28, 2014, Taylor El was noticed via text of the establishment of the EIN pending

incorporation of MOORISH SCIENCE TEMPLE 101 CALIFORNIA. See text and responses

between Najee-Ullah El and Taylor El dated March 25, 2014.Admit/ Without Knowledge/ Deny

7. Fact: As of the completion of this affidavit, MOOSISH SCIENCE TEMPLE 101 CALIFORNIA

including any names operated under during said collaboration, has made no attempt to have Califa

Media assigned to their control.


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8. Fact: Tauheedah S. Najee-Ullah El is the sole operator of Califa Media.Admit/ Without Knowledge/ Deny

9. Fact: Tauheedah S. Najee-Ullah El is the documented agent on all legal and lawful documents

pertaining to Califa Media.


10. Fact: Taylor El is unable to operate Califa Media due to his current lack of technical prowess.


11. Fact: Smith Bey is unable to operate Califa Media due to her current lack of technical prowess.


12. Fact: Should Najee-Ullah El cease contributing her time and talent to Califa Media, it will be

rendered non-functional.Admit/ Without Knowledge/ Deny

13. Fact: None of the books published by Califa Media credited to Victor Taylor El are his original

works.Admit/ Without Knowledge/ Deny

14. Fact: Victor Taylor El never had a CreateSpace Account as a publisher.Admit/ Without Knowledge/ Deny

15. Fact: Victor Taylor El never contributed to the online maintenance of Califa Media.


16. Fact: Victor Taylor El never contributed to the online promotion of Califa Media.Admit/ Without Knowledge/ Deny

17. Fact: Tauheedah S. Najee-Ullah El is the sole operator of Califa Media.Admit/ Without Knowledge/ Deny

18. Fact: Tauheedah S. Najee-Ullah El is the documented agent on all legal and lawful documents

pertaining to Califa Media.Admit/ Without Knowledge/ Deny

_________________________________

B. Corporate Documentation

1. Fact: On March 28, 2014 an EIN was requested by Najee-Ullah El for Califa Media banking use.

See redacted copy of EIN Confirmation for MOORISH SCIENCE TEMPLE CALIFORNIA, dba

CALIFA MEDIA.


2. Fact: Upon establishment of Califa Media by Najee-Ullah El, she transferred to this association

all copyrights for all unpaid works completed at the request of Taylor El. See Property List for

Califa Media Due to Failure to Reimburse.


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3. Fact: The images listed on the attached property list are revisions of images originally

commissioned by the Noble Prophet Drew Ali.Admit/ Without Knowledge/ Deny

4. Fact: The images listed on the attached property list are restorations completed by Sis.

Tauheedah S. Najee-Ullah El.Admit/ Without Knowledge/ Deny

5. Fact: Taylor El has never paid Najee-Ullah El for any work performed at his request, either

personally or on behalf of Moorish Science Temple 101 California, et.al.Admit/ Without Knowledge/ Deny

6. Fact: The MOORISH SCIENCE TEMPLE 101 CALIFORNIAs grand opening was March 29,

2014.


7. Fact: On April 5, 2014, Taylor El acknowledged to Najee-Ullah El that Califa Media was abranch of the Moorish Guide Publishing Company. See text dated April 5, 2014.


8. Fact: On April 5, 2014, Najee-Ullah El sent to Taylor El a proof of the trademark logo she created,

noting Califa Media is a Moorish Guide Publishing Company. See text dated April 5, 2014.


9. Fact: As of the completion of this affidavit, Moorish Science Temple 101 California et al, has

made no attempt to have recorded assignment of Califa Media to their control.


___________________________

C. Moors in America

1. Fact: On or about January 2014 Victor Taylor El brought to Tauheedah Najee-Ullah El black and

white copies of previously published works on Moorish history in America.


2. Fact: Cynthia Smith Bey was not present at this meeting


3. Fact: Cynthia Smith Bey has no direct knowledge of what then transpired.Admit/ Without Knowledge/ Deny

4. Fact: On or about January 2014 Taylor El left said materials with Najee-Ullah El with a request

to find color copies of all contents of the manuscript he left with Najee-Ullah EL.


5. Fact: Najee-Ullah used original content in compiling the manuscript which was later titled

Moors in America, (M.I.A.)


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6. Fact: The book was originally credited to Sis. Tauheedah S. Najee-Ullah El. Admit/ Without

Knowledge/ Deny

7. Fact: The book was later updated to include Bro. Victor Taylor El for reasons not disclosed to

Najee-Ullah El.


8. Fact: Cynthia Smith Bey was not present at this meeting.Admit/ Without Knowledge/ Deny

9. Fact: Cynthia Smith Bey has no direct knowledge of what then transpired.Admit/ Without Knowledge/ Deny

Fact: On or about February 17, 2014 Taylor El presented M.I.A. at Eso Won Book Store.


10. Fact: Due to the demand of M.I.A. Najee-Ullah El noticed Taylor El that she would look into a

publishing venue for M.I.A.Admit/ Without Knowledge/ Deny

11. Fact: Smith Bey was present, commenting that she had a friend who could provide books in

three or more weeks.


12. Fact: Najee-Ullah El, aware of Smith Beys tendency to procrastinate, endeavored to find a

publishing venue without the assistance of Smith Bey.


13. Fact: On February 22, 2014 a CreateSpace account was set up for the unincorporated associationknown as Calif a Media by Najee-Ullah El. See copy of email verifying account dated February 22,

2014.


14. Taylor El has an electronic copy of M.I.A.


15. Najee-Ullah is not preventing Taylor El from establishing his own publishing company.


________________________

D. Moslem Girls Training Guide

1. Fact: On or about October 2013, Taylor El loaned to Najee-Ullah El a Xeroxed copy of the Moslem

Girls Training Guide.Admit/ Without Knowledge/ Deny

2. Fact: Taylor El said it was standard issue to Muslim girls but that pieces were scattered.



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3. Fact: Tauheedah Najee-Ullah EL is a former member M.G.T.


4. Fact: On or about January 2014 Najee-Ullah El re-typed, proof-read and edited the copy of the

M.G.T. guide loaned to her by Taylor El.


5. Fact: Najee-Ullah El returned to Taylor El his copy of the M.G.T. Guide.


6. Fact: Taylor El has had access to the word file produced by Najee-Ullah El since its completion

January 2014.


7. Fact: Due to the lapse on the copyright for the book known as Moslem Girls Training Guide, this

work is now public domain.


8. Fact: Califa Media revised and republished Moslem Girls Training Guide as public domain work.


9. Fact: Another book entitled Muslem Girls Training Guide using identical material to the work

reissued by Califa Media was published in 2013 by Candance Shabazz. See print out of Amazon

book ad.Admit/ Without Knowledge/ Deny

10. Fact: There is nothing preventing Taylor El from publishing his own version of the M.G.T. Guide.Admit/ Without Knowledge/ Deny

11. Fact: There is nothing preventing Smith Bey from publishing her own version of the M.G.T.

Guide.


12. Fact: There is nothing preventing the Sisters Auxiliary of the Moorish Science Temple 101

California from publishing their own version of the M.G.T Guide.Admit/ Without Knowledge/ Deny

13. Fact: Victor Taylor El has never been a member of the M.G.T. Guide and has no sole publishing

rights over this book.


14. Fact: Cynthia Smith Bey has never been a member of the M.G.T. Guide and has no sole

publishing rights over this book.


15. Fact: Tauheedah Najee-Ullah EL was a member the M.G.T.


16. Fact: Califa Media republished the M.G.T. Guide as a work of public domain for other Moslems.


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17. Taylor El has an electronic copy of the M.G. T. Guide.


18. Najee-Ullah is not preventing Taylor El from establishing his own publishing company.


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E. Royalties

1. Fact: On or about March 2014, Taylor El relinquished his share of royalties to Najee-Ullah El

for the support of you and your children. See text stream dated June 9, 2014Admit/ Without Knowledge/ Deny

2. Fact: When Taylor El relinquished his portion of the royalties, Najee-Ullah El assured him the

Prophet would receive his 20%.Admit/ Without Knowledge/ Deny

3. Fact: Cynthia Smith Bey was not present at this meeting.Admit/ Without Knowledge/ Deny

4. Fact: Cynthia Smith Bey has no direct knowledge of what then transpired.


_______________________________________

F. Cynthia Smith Bey Not a Party to this Matter

1. Fact: On or about June 29, 2014, Cynthia Smith Bey confronted Najee-Ullah El regarding thelatter stealing from the Temple.


2. Fact: Smith Bey admitted that all dealings were between Najee-Ullah El and Taylor El.


3. Fact: Cynthia Smith Bey was not present at any meetings on the subject of Califa Media between

Taylor El and Najee-Ullah El.


4. Fact: Cynthia Smith Bey has no direct knowledge of any agreements or otherwise betweenTaylor El and Najee-Ullah El on the subject of Califa Media.


5. Fact: On June 29, 2014 Najee-Ullah El refused Smith Beys attempted ambush, demanding a

properly drafted and served complaint supported by evidence of the alleged theft.Admit/ Without Knowledge/ Deny


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6. Fact: Smith Bey cannot produce any evidence whatever supporting her ever being involved with

Califa Media in any capacity.


7. Fact: Cynthia Smith Bey is attempting to use the Moorish Science Temple 101 California as

vehicle to claim interest with Califa Media.


8. Fact: Califa Media is not an entity of the Moorish Science Temple 101 California.


9. Fact: Califa Media is a dba for the as yet unincorporated MOORISH SCIENCE TEMPLE

CALIFORNIA. See redacted confirmation of EIN assignment for MOORISH SCIENCE TEMPLE

CALIFORINIA dba CALIFA MEDIA.Admit/ Without Knowledge/ Deny

10. Fact: On June 29, 2014, Smith Bey sent to Najee-Ullah El a text stating the latter had admitted

to being a thief, among other allegations.


10. Fact: Affiant Tauheedah S. Najee-Ullah El rejects and rebuts every statement contained within

the text message sent by Smith Bey on or about June 29, 2014.Admit/ Without Knowledge/ Deny

11. Fact: Smith Bey cannot produce any evidence whatever supporting her allegation of theft by

Najee-Ullah El.Admit/ Without Knowledge/ Deny

12. Fact: Smith Bey cannot produce any evidence whatever supporting her allegation Najee-Ullah

El ever claiming to be a thiefAdmit/ Without Knowledge/ Deny

13. Fact: As of the completion of this affidavit, Moorish Science Temple 101 California including

any names operated under during said collaboration, has made no attempt to have recorded

assignment of Califa Media to their control.


WHEREFORE, LET IT BE KNOWN BY ALL MEN, Calfia Media is owned by the Prophet Noble

Drew Ali via the Hurds Revided Statutes (805 ILCS 110) and The Dead Mans Act (735 ILCS 5), see

generally. Sis. Tauheedah S. Najee-Ullah El is the sole operator of Califa Media, assigned as

registered agent for this association in the State of California/ California Republic. Sis. Tauheedah S.

Najee-Ullah El is the documented agent on all legal and lawful documents pertaining to Califa

Media.

Tauheedah Sabreen Najee-Ullah has been the only agent and operator of this association since its

inception. Victor Taylor El has in no way contributed to its daily operation or maintenance.


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Cynthia Smith Bey has not been privy to any information regarding this business outside of second

hand hearsay.

This notice and affidavit constitutes my efforts to resolve this ongoing claim as detailed below

Done this 30thDay of June, 2014.

/s/ Sis. Tauheedah S. Najee-Ullah El_________________

Sis. Tauheedah S. Najee-Ullah El

Address redacted for posting of public notice to social media

Contact [email protected] more information

I declare under penalties of perjury in accordance with the Holy Quran and the Holy Koran of the

Moorish Science Temple of America, the foregoing is true and correct and admitted when notrebutted.

Notice and Demand of Proof of Claim

Documents

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