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Affidavit of Randy Chapel

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7. Attached hereto as Exhibit G is a true and correct copy of the list by Carol Nye-Wilson, which was cross-referenced to the list found in Exhibit F. It contains many examples of

missing records intentionally not produced [demonstrates knowledge that records are problematic

to Defendant], which consist mostly of records harmful to the Defendant, two accreditors and

Western Seminary and mostly involve Chuck Mula.

8. Attached hereto as Exhibit H is a true and correct copy of the communicationbetween Plaintiff and Mr. Scharf regarding Carol Nye-Wilsons list.

9. Attached hereto as Exhibit I is a true and correct copy of the Retention ScheduleLocator Nos. 115 and 189 produced to Plaintiff by Mr. Scharf and referred to by Ms.

Siegelbaums Nov 10, 2011 letter.

10. Attached hereto as Exhibit J is a true and correct copy of Ms. Siegelbaums Nov10, 2011 letter, where she makes various denials to materials and misrepresentations regarding the

Retention Schedule Locator schedule.

11. Attached hereto as Exhibit K is a true and correct copy of pages 808 to 815 ofFOIA Request No. 11-01901-F produced on Oct 07, 2011.

12. Attached hereto as Exhibit L is a true and correct copy of pages 1959 to 1985 ofFOIA Request No. 11-01474-F produced on Oct 07, 2011. These records include not only my

complaint to the Feds regarding Western and ATS teaming up together against my mother and me

in violation of 34 C.F.R. 602.15, but also my attorneys warning letter to Westerns attorney

regarding these actions and the on going violation by ATS and Western. The Court should note

that these records come from Terry Bashford of the OGC, who no communication was addressed

to from Mr. Wiener, myself or Tom Johnson. However, Mr. Bashford has these records and more

interestingly ATS attorneys contact information (index 1979), which Siegelbaum claimed the

Department did not have and proceed to bare the Departments teeth regarding to refuse to turn

over any records at all. Shortly after I filed a complaint against ATS, everything magically went

away.

13. Attached hereto as Exhibit M is a true and correct copy of 636-644 of FOIARequest No. 11-014074-F produced on Oct 20, 2011.

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Affidavit of Randy Chapel

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I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct. This affidavit was executed this _______ day of November 2011,

and signed under the laws of California.

I, Randy Chapel, sign this AFFIDAVIT in the County of Santa Cruz, in the State of California.

________________ _______________________________________

Date Randy Chapel

I, __________________________________________ am a Notary Public in the County of

___________________ in the State of California.

I have witnessed the signing of this AFFIDAVIT by Randy Chapel who appeared before me on

__________________ and she showed me photo ID. My Notary Public Commission Number is

______________________________. My Notary Public Commission expires on

______________________________.

S E A L