{UAH} UNAA's Response to Motion for Judgment on Pleadings

Highlights of UNAA leaders' response to my motion for Judgment on the Pleadings:

1. they mailed their package on August 6th, 2015 but their lawyer swore on a certificate of service that he mailed it on July 28, 2015. Either way, it was late but we will not oppose it because we want the court to rule on the case as soon as possible.

2. UNAA's website shows that in 2014, UNAA had 117 members. But in the response to my motion, UNAA leaders are claiming that in 2014, UNAA had 1,395 members! They claim that the 117 on unaa.org "does not include discounts, specials or exemptions". Under Article 3:3 of UNAA constitution, ALL members are required to pay a membership fee. In their response, UNAA leaders do not explain how any members got discounts on membership fees, or how some members got a special deal on membership or how some members were exempted from paying the membership fees!  

Either UNAA leaders are lying to court that membership is more than 117 or they are lying to their members by hiding unknown members' registers.  As part of the discovery process, we will force them to show the list and addresses of all the members. FYI, UNAA had 156 members in 2011, 73 in 2012 and 440 in 2013.

4. UNAA leaders state that "the 117 was accurate as of 2014, during a period when UNAACauses was diverting substantial member participation due to name confusion.  Thus membership dues reflected at that date are unlikely to represent UNAA's true membership"!!!  This a strange argument because UNAA's fiscal calendar used to run from Sept to Aug (in April 2015, Mr Brian Kwesiga and his current "Board" changed the fiscal calendar to run from Jan to Dec).  The 2014 fiscal year run from September 1, 2013 and closed on August 31, 2014.  Therefore, membership dues paid during the fiscal year ending Sept 2014 would reflect the true true membership. According to UNAA's website, that number is 117.

3. they do not mention any person that paid a membership fee to UNAACauses in instead of paying it to UNAA. 

3. Though Mr Abe and I were not in leadership in 2013, UNAA leaders claimed in the response to our motion that they "ousted" us from leadership.

4. UNAA leaders lied to the court that every UNAA member that has my last name is my family member! This is very strange because they know some of these people.

5. they lied to the court that Mr. Abe and I "were involved in the creation of UNAACauses", that I am the General Counsel of UNAACauses.

8. they lied that UNAA lost membership dues because members did not come to the annual meeting in San Diego.  However, they did not mention that membership dues are not refundable!  Thus, UNAA keeps the membership fee even if the member doesn't come to the meeting.

9. UNAA leaders claim that we blocked members from voting at the 2014 annual meeting and repeatedly encouraged members to split from UNAA.  But they do not name a single person that that we stopped voting. They do not mention any person that we encouraged to "split from UNAA".

 

For a faster response please contact me at 415.789.6427

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