Federal Response from Vice-President IBC/UHJ

Timothy P. Getzoff, Holland &Hart LLP 600 East Main St. Suite 104, Aspen, CO 81611 or email to: tgetzoff@hollandhart.com “O ye beloved of the Lord! In this sacred Dispensation, conflict and contention are in no wise permitted. Every aggressor deprives himself of God's grace. It is incumbent upon everyone to show the utmost love, rectitude of conduct, straight forwardness and sincere kindliness unto all the peoples and kindreds of the world, be they friends or strangers. So intense must be the spirit of love and loving kindness, that the stranger may find himself a friend, the enemy a true brother, no difference whatsoever existing between them.” (pg. 13, W&T).

Requests for Documents and Things 1. The only agreement between I, Kay Woods, and IBC/UHJ, is my Declaration of Belief (please see EXHIBIT 1) as expressed through the sacred charter of the Baha'i faith titled “The Kitab-iAhd” (The Book of the Everlasting Covenant of God), and “The Will and Testament of Abdu'lBaha” (I understand that this document already exists in your file; please see Exhibit A submitted by Dr. Neal Chase). According to this century-old document, I have a right and a franchise to teach my belief about the Baha'i covenant, as I understand it, regardless of a registered trademark. This document gives me that right.

“In these days, the most important of all things is the guidance of the nations and peoples of the world.

Teaching the Cause is of utmost importance for it is the head cornerstone of the foundation itself.” (pg.

10, W&T) This document explains what comprises the true,“Universal House of Justice”. Specifically, for the true, “Universal House of Justice” to be authentic, it must have as its president the “Aghsan” Branch (male, lineal descendant of King David), the “irremovable member for life of that body”(Will & Testament, pg. 14), appointed by the previous guardian.

“O ye beloved of the Lord! It is incumbent upon the guardian of the Cause of God to appoint in his own life-time him that shall become his successor, that differences may not arise after his passing.” (pg. 12, W&T).

My firm belief in the Baha'i covenant, particuarly the guardianship aspect of the covenant, is rooted in the old testament covenant (promise) that the line of David is continuous, unending, and everlasting: “Thy Kingdom come, thy will be done...” That promise is fulfilled in, and through, the Baha'i covenant. God does not break His own covenant. Humans break the covenant. The history of the “Hands” breaking the Baha'i covenant is exhaustive, and too detailed to mention here.

This “Universal House of Justice”, with the Aghsan branch or guardian at its head, is what specifically distinguishes it from all other fraudulent versions of the Baha'i “Universal House of Justice.” If it doesn't have the guardian as its executive branch or president, it is not the true and complete “Universal House of Justice” and is not in accordance with Abdu'l-Baha's Will and Testament. Dr. Neal Chase is the current guardian of the Baha'i faith, executive Aghsan Branch who meets the specific criteria given in the Will and Testament of being a son, and being appointed by the previous Aghsan guardian, Joseph Pepe Remey. See also photo of genealogy of Baha'u'llah, attached.

“The Most Great Law is come, and the Ancient Beauty ruleth upon the throne of David. Thus hath My Pen spoken that which the histories of bygone ages have related.” --Baha'u'llah; Proclamation of Baha'u'llah, pg. 89.

When Dr. Leland Jensen established the second International Baha'i Council on March 2, 1991, and appointed its original members (see photo of original members, attached), he positioned Neal Chase in the place of president (“heir apparent”) directly under the liaison officer position (see photo of IBC minutes, attached); his role as guardian did not officially go into effect until the passing of the previous Aghsan guardian, Joseph Pepe Remey, in 1994.

2. The only agreement between I, and the defendant, Dr. Neal Chase, is that as a member of the second International Baha'i Council being firm in the Baha'i covenant, I “assent” to his position as the appointed successor to the Aghsan guardianship, executive branch of the IBC (pg. 12 of the W&T), and I “reinforce” that position, as stated on pg. 15 of the Will.

“The legislative body must reinforce the executive, the executive must aid and assist the legislative body so that through the close union and harmony of these two forces, the foundation of fairness and justice may become firm and strong, ...” (pg. 15, W&T) “It is incumbent upon the members of the House of Justice, upon all the Aghsan (male-lineal descendants of Baha'u'llah), the Afnan, the Hands of the Cause of God to show their obedience, submissiveness and subordination unto the guardian of the Cause of God...” (p. 11, W&T) 3. I understand that the document showing the terms of agreement between Dr. Neal Chase and the IBC/UHJ has already been submitted as Exhibit A (the Baha'i Covenant and Will and Testament of Abdu'l-Baha).

4. I possess no documents constituting or relating to communications I have had with any person concerning the lawsuit captioned NSA v. Neal Chase, Civil Action No. 21, etc.

5. I possess no document constituting or relating to communications I have had with any person concerning United States Application, etc., for the UHJ mark.

6. I possess no document constituting or relating to communications I have had with any person concerning the USPTO Trademark Trial and Appeal Board Opposition No. 91173793.

7. Please see EXHIBIT 2: Description of Vice-President, from the Book of Order of the Second International Baha'i Council.

8. Please see EXHIBIT 3: Description of President, from the Book of Order of the Second International Baha'i Council.

9. I possess no such document; we hold our annual “corporate meeting” on the Baha'i Holy Day of April 21 during the Ridvan period, to declare our membership, which we have been doing every year since prior to 2006.

10. I possess no such notes, we meet annually to declare our membership.

11. I possess no such electronic mail messages related to IBC/UHJ business; we meet annually in person to declare our membership.

12. I possess no such documents identifying employees (as we have none), or executive, or Board Members of IBC/UHJ from 2006 to present, as these documents are contained in the State of Colorado Corporate Database, which I do not have access to.

13. The IBC/UHJ possesses no bank accounts registered in the State of Colorado.

14. I possess no documents showing IBC/UHJ tax filings, as the IBC/UHJ is a non-profit, tax exempt corporation and does not file state and federal taxes.

15. I possess no documents showing donations made to IBC/UHJ, as no donations are made to this entity.

16. I possess no documents showing operating expenses for IBC/UHJ. 17. I possess no documents showing solicitation of donations to IBC/UHJ, as no donations are made to this entity.

18. Other than the Will and Testament of Abdu'l-Baha, I possess no document showing my activities in connection with use of the mark, “Universal House of Justice.”

19. Other than the Will and Testament of Abdu'l-Baha, I possess no document concerning the IBC/UHJ's activities in connection with use of the mark, “Universal House of Justice.”

20. Other than the Will and Testament of Abdu'l-Baha, I possess no documents related to Dr. Neal Chase's activities in connection with use of the mark, “Universal House of Justice.”

21. I possess no documents related to my activities in connection with use of the mark, “UHJ”.

22. I possess no documents concerning use of the mark, “UHJ”, by the IBC/UHJ. 23. I possess no documents concerning use of the mark, “UHJ”, by Dr. Neal Chase.

24. I possess no such documents, as I do not own or control any website under the mark, “The Universal House of Justice”, on which goods and services are promoted.

25. I possess no such documents, as I do not own or control any website under the mark, “UHJ”, on which goods and services are promoted.

26. I possess no such documents, as IBC/UHJ does not own or control any website, on which goods and services are promoted under the mark, “Universal House of Justice”.

27. I possess no such documents, as IBC/UHJ does not own or control any website, on which goods and services are promoted under the mark, “UHJ”.

28. I possess no such documents as Dr. Neal Chase does not own or control any website, on which goods and services are promoted under the mark, “The Universal House of Justice”.

29. I possess no such documents as Dr. Neal Chase does not own or control any website, on which goods and services are promoted under the mark, “UHJ”.

30. Besides the Will and Testament of Abdu'l-Baha, I possess no documents or copies of documents identifying agreements between myself and a third party, concerning use of the mark, “The Universal House of Justice”, in the United States.

31. I possess no documents or copies of documents identifying agreements between myself and a third party, concerning use of the mark, “UHJ” in the United States.

32. Besides the Will and Testament of Abdu'l-Baha, I possess no documents or copies of documents identifying agreements between IBC/UHJ and a third party, concerning use of the mark, “The

Universal House of Justice”, in the United States.

33. I possess no documents or copies of documents identifying agreements between IBC/UHJ and a third party, concerning use of the mark, “UHJ”, in the United States.

34. Other than the Will ad Testament of Abdu'l-Baha, I possess no documents or copies of documents identifying agreements between Dr. Neal Chase and a third party, concerning use of the mark, “The Universal House of Justice”, in the United States.

35. I possess no documents or copies of documents identifying agreements between Dr. Neal Chase and a third party, concerning the use of the mark, “UHJ”, in the United States.

36. I possess no documents constituting or relating to communications I have had with any person about NSA or NSA's marks, “The Universal House of Justice”, and/or “UHJ”.

37. I possess no documents relating to the registration or use of the uhj.net domain.

38. I possess no documents constituting or relating to communication I have had with any other person about the uhj.net domain, including the registration of the domain name, or renewal of the registration of the domain name.

39. I possess no documents constituting or relating to communications I have had with any other person about the website that resolves at the uhj.net domain name (the “UHJ Website”).

40. I possess no documents containing data or statistics concerning website traffic to the “UHJ website”, including number of visitors, etc.

41. I possess no documents to show payments for the registration and renewal of the registration of t he uhj.net domain name from the first registration of the domain until the latest renewal, including documents that show the individual(s) or entity who made the payments.

42. I possess no documents concerning the design, maintenance, and/or posting of content to the “UHJ website” as I do not design, maintain, or post content to the website.

43. I possess no documents to show current and complete WhoIs information for the uhj.net domain name.

44. I possess no documents to show changes or edits to the WhoIs information for the uhj.net domain name.

45. I possess no documents constituting or relating to communications I received but intended for NSA. 46. I possess no documents constituting or relating to communications received by IBC/UHJ but intended for NSA. 47. I possess no documents constituting or relating to any communication as to whether IBC/UHJ or IBC/UHJ's goods or services are somehow affiliated with NSA. 48. I possess no documents constituting or relating to any communication to me, as to whether Dr. Neal Chase or his goods or services are affiliated with NSA in any manner.

49. I possess no documents constituting or relating to any communication to me, as to whether NSA or NSA's goods or services are affiliated with IBC/UHJ in any manner.

50. I possess no documents constituting or relating to any communication to me, as to whether NSA or NSA's goods or services are affiliated with Dr. Neal Chase in any manner.

EXHIBIT 1.

Declaration of Belief I acknowledge I have read Entry By Troops and I declare my belief in the Covenant of Baha'u'llah as

delineated by ‘Abdu'l-Baha in his sacred Will and Testament and constituted by Shoghi Effendi as the first International Baha'i Council/Universal House of Justice (IBC/UHJ) which was embryonic and is now born into the world as the second International Baha'i Council/Universal House of Justice with the living Guardian as its head which will evolve into a World Court, and International Tribunal and then the Universal House of Justice (elected from National Houses of Justice) with the living Guardian as its president and irremovable member for life in all its stages. I recognize that infallibility has been conferred upon this House of Justice, in all its stages, through the Lesser Covenant of God and also upon the Establisher of the Baha’i Faith, Dr. Leland Jensen, through the Greater Covenant of God. I, moreover, give my fealty and loyalty to every single provision of the Master’s sacred Will and Testament of ‘Abdu’l-Baha, and in doing so, thereby, acknowledge and recognize the great grandson of ‘Abdu’l-Baha, Neal Chase ben Joseph Aghsan, as the current living president of the IBC/UHJ, and current living Guardian of the Baha’i Faith seated upon the throne of King David which is to last forever.

EXHIBIT 2. “Powers, Duties and Authority of the Vice-President The main function of the vice-president as provided for in the pattern set forth in Shoghi Effendi's constitution for the second International Baha'i Council is to take care of the order of business while the guardian is incapacitated and cannot attend. The vice-president does not succeed the guardian when he dies. The vice-president cannot appoint the next guardian.”

(Book of Order of the Second International Baha'i Council, pg. 67, “Powers, Duties and Authority of the President and Vice-President”) EXHIBIT 3. “Powers, Duties and Authority of the President The powers of the president, entitled the guardian of the Cause of God, are that of the executive branch and irremovable member for life of the second International Baha'i Council/Universal House of Justice as explained on page 14 and 15 of the Will and Testament of 'Abdu'l-Baha.”

(Book of Order of the Second International Baha'i Council, pg. 67, “Powers, Duties and Authority of the President and Vice-President”) “The Most Great Law is come, and the Ancient Beauty ruleth upon the throne of David. Thus hath My Pen spoken that which the histories of bygone ages have related.” --Baha'u'llah.

Certificate of Service I certify that a true and accurate copy of this document (with attachments) was electronically emailed and addressed to the following parties on March 8, 2022: Timothy P. Getzoff Holland & Hart LLP 1800 Broadway, Suite 300

Boulder, CO 80302 Email: tgetzoff@hollandhart.com Respectfully submitted by: Kay Woods Vice-President, second International Baha'i Council P.O. Box 682 Paonia, CO 81428 Email: kwoodspirit@yahoo.com