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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 El
Address 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
****************************************************************************
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 30
th
Day 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

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 rebutted
without 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.
Admit/ Without Knowledge/ Deny

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
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

10. Fact: Taylor El is unable to operate Califa Media due to his current lack of technical prowess.
Admit/ Without Knowledge/ Deny

11. Fact: Smith Bey is unable to operate Califa Media due to her current lack of technical prowess.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

7. Fact: On April 5, 2014, Taylor El acknowledged to Najee-Ullah El that Califa Media was a
branch of the Moorish Guide Publishing Company. See text dated April 5, 2014.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny


___________________________
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.
Admit/ Without Knowledge/ Deny

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

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.
Admit/ Without Knowledge/ Deny

5. Fact: Najee-Ullah used original content in compiling the manuscript which was later titled
Moors in America, (M.I.A.)
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

12. Fact: Najee-Ullah El, aware of Smith Beys tendency to procrastinate, endeavored to find a
publishing venue without the assistance of Smith Bey.
Admit/ Without Knowledge/ Deny

13. Fact: On February 22, 2014 a CreateSpace account was set up for the unincorporated association
known as Calif a Media by Najee-Ullah El. See copy of email verifying account dated February 22,
2014.
Admit/ Without Knowledge/ Deny

14. Taylor El has an electronic copy of M.I.A.
Admit/ Without Knowledge/ Deny

15. Najee-Ullah is not preventing Taylor El from establishing his own publishing company.
Admit/ Without Knowledge/ Deny

________________________
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.
Admit/ Without Knowledge/ Deny

3. Fact: Tauheedah Najee-Ullah EL is a former member M.G.T.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

5. Fact: Najee-Ullah El returned to Taylor El his copy of the M.G.T. Guide.
Admit/ Without Knowledge/ Deny

6. Fact: Taylor El has had access to the word file produced by Najee-Ullah El since its completion
January 2014.
Admit/ Without Knowledge/ Deny

7. Fact: Due to the lapse on the copyright for the book known as Moslem Girls Training Guide, this
work is now public domain.
Admit/ Without Knowledge/ Deny

8. Fact: Califa Media revised and republished Moslem Girls Training Guide as public domain work.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

15. Fact: Tauheedah Najee-Ullah EL was a member the M.G.T.
Admit/ Without Knowledge/ Deny

16. Fact: Califa Media republished the M.G.T. Guide as a work of public domain for other Moslems.
Admit/ Without Knowledge/ Deny

17. Taylor El has an electronic copy of the M.G. T. Guide.
Admit/ Without Knowledge/ Deny

18. Najee-Ullah is not preventing Taylor El from establishing his own publishing company.
Admit/ Without Knowledge/ Deny

---------------------------------------
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, 2014
Admit/ 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.
Admit/ Without Knowledge/ Deny


_______________________________________
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 the
latter stealing from the Temple.
Admit/ Without Knowledge/ Deny

2. Fact: Smith Bey admitted that all dealings were between Najee-Ullah El and Taylor El.
Admit/ Without Knowledge/ Deny

3. Fact: Cynthia Smith Bey was not present at any meetings on the subject of Califa Media between
Taylor El and Najee-Ullah El.
Admit/ Without Knowledge/ Deny

4. Fact: Cynthia Smith Bey has no direct knowledge of any agreements or otherwise between
Taylor El and Najee-Ullah El on the subject of Califa Media.
Admit/ Without Knowledge/ Deny

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

6. Fact: Smith Bey cannot produce any evidence whatever supporting her ever being involved with
Califa Media in any capacity.
Admit/ Without Knowledge/ Deny

7. Fact: Cynthia Smith Bey is attempting to use the Moorish Science Temple 101 California as
vehicle to claim interest with Califa Media.
Admit/ Without Knowledge/ Deny

8. Fact: Califa Media is not an entity of the Moorish Science Temple 101 California.
Admit/ Without Knowledge/ Deny

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.
Admit/ Without Knowledge/ Deny

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 thief
Admit/ 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.
Admit/ Without Knowledge/ Deny


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.
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 30
th
Day 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 califamedia@gmail.com for 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 not
rebutted.

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