Full page photo - Joe Collins for Congress · 2021. 2. 20. · • DEPARTMENT OF VETERANS AFFAIRS 810 Vermont Ave NW Washington, D.C. 20420 February 11, 2021 Joe Edward Collins 3680

1 Donna Bullock

2 Attorney at Law (SBN 109223) 800 W. 6th St., Ste. 1250

3 Los Angeles, CA 90017 Tel: (562) 726-0778

4 Fax: (562) 683-0319

5 [email protected]

6 Attorney for Plaintiff JOE E. COLLINS III

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

JOE E. COLLINS III, ) )

Plaintiff, ~ ) )

Vs. ) )

MAXINE WATERS, an individual; MAXINE~ WATERS FOR CONGRESS, form unknown; ) DOES 1 to 200, Inclusive, )

)

Defendants ~

Case No: 20STCV37401

SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS III IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION AND IN OPPOSITION TO DEFENDANTS' UNTIMELY AND IMPROPER SPECIAL MOTION TO STRIKE COMPLAINT

Date: February 17, 2021 Time: 8:30 a.m. Dept: 31

SUPPLEMENTAL DECLARATION OF JOE COLLINS

I, JOE COLLINS, declare as follows:

1. That I am the Plaintiff in the above-captioned action. If called upon as a witness in

this action I could and would testify competently to the following facts.

2. That I had requested additional documentation of my military discharge status. I di

this despite the fact that my DD-214 is the Official Record of my military discharge on my final

date of active duty from the United States Navy was October 27, 2017, my DD-214 was dated

and issued on October 27, 2017 and it was, at all times since my discharge, a General Discharge

under Honorable Conditions.

- 1 -SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS III IN SUPPORT OF EX PART£ APPLICATION TO STRJKE ANSWER AND ANTI-SLAPP MOTION, etc.

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3. Attached hereto, marked as Exhibit "A" and incorporated herein by this reference is

a true and correct copy of a February 11 , 2021 letter from the Department of Veterans Affairs

certifying my discharge as under Honorable Conditions.

4. Attached hereto, marked as Exhibit "B" and incorporated herein by this reference is

a true and correct copy of a February 11, 2021 document from the Department of Veterans

Affairs providing me with a Verification of Honorable Service identification card.

5. Attached hereto, marked as Exhibit "C" and incorporated herein by this reference is

a true and correct copy of a February 11 , 2021 document from the Department of Veterans

Affairs certifying and confirming my civil service Veteran's Preference for employment

application purposes.

6. Attached hereto, marked as Exhibit "D" and incorporated herein by this reference is

a true and correct copy of a February 11, 2021 document from the Department of Veterans

Affairs letter confirming my enrollment in the VA Health Care System based upon the

Honorable character of my military discharge.

7. Attached hereto, marked as Exhibit "E" and incorporated herein by this reference is

a true and correct copy of a July 30, 2019 Benefits Statement from the Department of Veterans

Affairs letter confirming my 85% service related disability and other benefits based upon the

Honorable character of my military discharge.

8. Attached hereto, marked as "F" and incorporated herein by this reference is a fake

ballot, which is a piece of campaign literature prepared by Defendants CITIZENS FOR

WATERS and WATERS, which gives me the caption on what appears to be in the format of an

election ballot defaming me with a describing my qualifications with the false statement

"dishonorable discharge US Navy." This campaign advertisement was published after

Defendants were served on October 2, 2020 and before the November 3, 2020 General Election,

at a time Defendants had been informed that their statement about my discharge status was false.

9. Attached hereto, marked as "G" and incorporated herein by this reference is tweet

from Defendant MAXINE WATERS which contains the false claim about my military discharge

status, false claims about fundraising, and other false claims. This tweet is dated November 5,

- 2 -SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS III IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

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2020, after Defendant WATERS won the election and for no legitimate reason other than to

attempt to humiliate me.

I 0. Attached hereto, marked as "H" and incorporated herein by this reference is my

own tweet to Defendant MAXINE WATERS confirming that her people were demanding I drop

this "defamation lawsuit."

I declare under penalty of perjury that the foregoing is true and correct, and that this

declaration is executed on February 16, 2021 in Los Angeles County, California.

Isl Joe Collins -----------

JOE E. COLLINS III, declarant

- 3 -SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS Ill IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

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EXHIBIT 'A'


February 11 , 2021

Joe Edward Collins 3680 Wilshire Step04 1180 Los Angeles, CA 90010

Dear Mr. Collins:

DEPARTMENT OF VETERANS AFFAIRS 810 Vermont Ave NW

Washington, D.C. 20420

In Reply Refer to: xxx-xx-1830 27 /eBenefits

This letter certifies that Joe Edward Collins was discharged from the U.S Armed Forces having served during the following period(s):

Branch of Service Entered· Active Duty Discharged Character of Service

Navy August 11 , 2004 October 27, 2017 Under Honorable Conditions

(You may have additional periods of service not listed above.)

How You Can Contact Us

• If you need general information about benefits and eligibility, please visit us at https://www.ebenefits.va.gov or http:llwww.va.gov.

• Call us at 1-800-827-1000. If you use a Telecommunications Device for the Deaf (TDD), the number is 1-800-829-4833.

• Ask a question on the Internet at https://iris.custhelp.va.gov.

Sincerely,

Cheryl J Rawls Assistant Deputy Under Secretary for Field Operations Office of Outreach and Stakeholder Engagement

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EXHIBIT 'B'

- 5 -

SUPPLEMENT AL DECLARATION OF PLAINTIFF JOE E. COLLINS Ill IN SUPPORT OF EX P ARTE APPLICA TJON TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

• DEPARTMENT OF VETERANS AFFAIRS

810 Vermont Ave NW Washington, D.C. 20420

February 11, 2021


Dear Mr. Collins:

In Reply Refer to: xxx-xx-1830 27/eBenefits

Please use the cut-out card below as verification of your honorable service in the Uniformed Services of the United States.

<front of card> <back of card>

r------------------------------------1 This card is to serve as proof the individual listed below served honorably in the Uniformed Services of the United States.


Effective as of: February 11 , 2021 DoD ID Number: 1257798379 Date of Birth: November 20, 1985 Branch Of Service: Navy

United States of America Department of Veterans Affairs

General Benefit Information 1-800-827-1000

Health Care Information 1-877-222-VETS (8387)

This card does not reflect entitlement to any benefits administered by the Department of Veterans Affairs or serve as proof of receiving such benefits.

~-----------------~------------------~

Do You Have Questions or Need Assistance?

If you have any questions, you can contact us by telephone or Internet.

If you want to Telephone

Use the Internet

Here is what to do. Call us at 1-800-827-1000. If you use a Telecommunications Device for the Deaf (TDD), the number is 711 . Send electronic inquiries through the Internet at https://iris custhelp.va gov.

Within eBenefits, you can change your address or direct deposit, check the status of your claim, obtain a copy of your DD 214, and access additional VA benefit information at

http://benefits.va.gov/benefits/.

You can find health benefit information at http://www.va.gov/healthbenefits/.

Sincerely,


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EXHIBIT 'C'

- 6 -

SUPPLEMENT AL DECLARATION OF PLAINTIFF JOE E. COLLINS III IN SUPPORT OF EX P ARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

February 11 , 2021


Dear Mr. Collins:

DEPARTMENT OF VETERANS AFFAIRS 810 Vermont Ave NW

Washington, D.C. 20420

In Reply Refer to: xxx-xx-1830 27 /eBenefits

This letter is furnished to support your consideration for Veterans' preference as you seek Federal civil service employment.

What Our Records Show

The Department of Veterans Affairs records certify that you separated under honorable conditions from active duty military service and that you are entitled to compensation for service-connected disability(ies) which are at least 30 percent or more disabling. Your payment i$ made in accordance with public laws administered by the Department of Veterans Affairs.

How You Can Contact Us

• If you need general information about benefits and eligibility, please visit us at https://www.ebenefits.va.gov or http://www.va.gov.

• Call us at 1-800-827-1000. If you use a Telecommunications Device for the Deaf (TOD), the number is 1-800-829-4833.

• Ask a question on the Internet at https://iris.custhe!p.va.gov.

Sincerely,


Enclosure: Standard Form 15

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EXHIBIT 'D'

- 7 -

SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS III IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

February 11 , 2021


Dear Mr. Collins:

DEPARTMENT OF VETERANS AFFAIRS

I am pleased to confirm your enrollment in the Department of Veterans Affairs (VA) health care system. Your enrollment satisfies the requirement to have health care coverage under the Affordable Care Act, which you may know as "ACA" or "health care law".

What This Means to You

• You have access to comprehensive health care services at VA facilities anywhere in the country. You can use these services even if you have Medicare, Medicaid, TRICARE, or private health insurance coverage.

• There are no enrollment fees, monthly premiums, or deductibles. However, you may have to pay VA small copayments for your health care or medications.

• You do not have to take any action to renew your annual enrollment status. VA will notify you if anything changes in your enrollment.

• You do not need to take additional steps to meet the health care law coverage standards.

Family Members Not Eligible for VA Coverage

ACA has created a Health Insurance Marketplace where you may explore health coverage options. Your family members who are not enrolled in a VA health care program may use the Marketplace to obtain coverage. They may be eligible for lower monthly premiums or reduced out-of-pocket costs. They could also be eligible for free or lowcost coverage through Medicaid or the Children's Health Insurance Program (CHIP). Starting October 1, 2013, an application for health care coverage can be submitted through the Marketplace. For more information, visit www.healthcare.gov.

Where Can You Get More Information

If you have any questions, contact us toll-free at 1-877-222-VETS (8387). You can also find additional information on eligibility and enrollment on VA's website at www.va.gov/aca.

Thank you for your service to our Nation.

Sincerely,

Lynne Harbin Deputy Chief Business Officer, Member Services

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28 EXHIBIT 'E'


Juty 30. 2019

DEPARTMENT OF VETERANS AFFAIRS 110 Vtlffl'tOnt Ave NW

WNhlngtoft. D.C. 2CM20

In Reply Rar to:

lM Angelfl. CA 90010

XJIOl-DM 1830 27/eBenefits

o.a, Mr. comn1:

Thi• let« I• a urvnary of benefde you eutrently ~ from the OepaJ1ment of Veteran, Affaitt (VA). W. n p!'OVll'ing 1h11 letter to dlabled Vetetw to ua in •pplyfng for benefits u:h u state or tocat pope,ty or whicte tu retef, dVIJ 1en,tce preference, to obtain housing emfflements, free or lllduced acate p;n annua memberahlpa. or any othef' p,ogrem or entftlement in which wrtflcation of VA berleffll II n,quirect Pleue ufegua,d this lmpo,tent document Thll lettet is contk!Mld an official !'HOid of )'OUr VA entltMmer1t

Our recon:11 conllin th• tolowing infonnatlon:

Person1I Clalm Information Your VA cla m runbef· 11:

You n the Veterm

Military lnfonnltlon Your most re<:ent. verified periods of •rw;e (US) to 1hrH) tndude~

Bl'MCh Gf 84Jrva CblrK'Wof letvlc:. EnlllNCIActM Ocaty Navy under Honorable CondMOnl Augl.llf 11 , 2004

(There may be adclllticNt periods of llf'VICe not IIIIN above.)

VA Benefit Information

You~ or-.orm<nNff~d.lMbftlhl: Your combined ~tad evaluatlan la:

You.,. belng paid at the 100 percentra• bee.I.,... you ar. ~_. to yOUl'MMce4CM■-ted cllNl:,lltfN:

You.,. cOMldefWd to be tofalty and ptlfflllNlflttr dlublect due•~ to your Hf'Ylce<CN•..-.d dlubllliN:

RettaNdllllldlarged October27, 2011

Yn

Thlt 6ctmt dalt of wt.rt you mcame tabllly and pennarw,lly clsaliled due to October 28• 2017 ,OWNrVl~•IMldlNMIUN:

You lhol.id contact your lbltJt or local ab of Vetsans• •Iran tor tnformation on an, ta,c. lieenM, or ,__related betletftl for Which~ mav be elilible. State offices of Velerlna' affilh are avalable • httpJ{W'ft.ya,ggyl&tatedVa.htm.

n.-:v.:,. ~ . · · You Can Contact U. ~ 0

• JOU need gene,al 1nfomlalton aboUt l:N!tneltl.and dslllllJ. plUN Yisltua •tt•;JO'fJdf lhot011.&IAY « ~~~·

,■ • ~ 62 7 Comments

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EXHIBIT 'F'

- 9 -SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLLINS Ill IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

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EXHIBIT 'G'

- 10 -SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE E. COLUNS III IN SUPPORT OF EX PARTE APPLICATION TO STRIKE ANSWER AND ANTI-SLAPP MOTION, etc.

1v1e1x1ne waters •

@Maxine Waters

la US House candidate, CA-43

V

The Repubs tried it again! They raised $1 O m to try & defeat mew/ a candidate who was dishonorably discharged from the Navy & was a deadbeat dad refusing to pay child support for 4 different children in 4 different states. We have the receipts & we're sharing them w/ everybody! 5:17 PM · 05 Nov 20 · Twitter for iPhone

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EXHIBIT 'H'


~;.;;J,J¾.N_,:::~,.~am.~ct.iiiltifoilM,...UWt£<l:%ltw1'. wmat:10&\Ji'.~~~:

Joe Collins ·- 3m • 0

•••

Hey Maxine Waters g,uess what! I know you had people coming to my office asking me to drop my lawsuit agai1nst you but trust and believe I didnt drop that defamation lawsuit and you're making this case stronger every time you open your mouth about me! See ya in court!!!

Try sharing this post to your Page's story. ( SHARE TO STORY )

0 0 Kelle Rene and 1.2K others 98 Comments 63 Shares ,w

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PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the county of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 800 W. 6th St., Ste. 1250, Los Angeles, CA 90017.

5 On February 16, 2021 , I served the foregoing document described as:

SUPPLEMENTAL DECLARATION OF PLAINTIFF JOE COLLINS IN SUPPORT OF EX 6 PAR TE APPLICATION TO STRIKE ANTI-SLAPP MOTION AND ANSWER FILED AFTER

ENTRY OF DEFAULT AGAINST DEFENDANTS, ETC. 7

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On the interested parties in this action by electronically transmitting a true and correct copy thereof as follows:

Gary W. Lincenberg, Esq. [email protected] Thomas V. Reichert, Esq. [email protected] BIRD, MARELLA, BOXER, WOLPERT, NESSIM DROOKS, LICENBERG & RHOW, P.C. 1875 Century Park East, 23rd Floor Los Angeles, CA 90067-2561 Fax: (310) 201-2110

XX (BY ELECTRONIC MAIL) I electronically served the foregoing described documents to the persons and electronic service addressed of the persons listed above.

(State) I declare under penalty of perjury under the laws of the state of California that the above is true and correct.

Executed on February 16, 2021 , at Los Angeles, California.

Donna Bullock Print Name

Isl Donna Bullock --------Signature


Documents

Full page photo - Joe Collins for Congress · 2021. 2. 20. · • DEPARTMENT OF VETERANS AFFAIRS 810 Vermont Ave NW Washington, D.C. 20420 February 11, 2021 Joe Edward Collins 3680