Case 4:19-cv-04577-JSW Document 418 Filed 10/06/25 Page 1 of 3
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`UNITED STATES DISTRICT COURT ~
`NORTHERN DISTRICT OF CALIFORNIA ~ OCT =6 202
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`In the Matter of: CLERk 7 U, DISTRICT COURT
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`Lopez v. EL v. Apple Inc. (2021) NORTH DISTRICT OF CAY INIA
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`Case No. 4:19-cv-04577-ISW
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`AFFIDAVIT OBJECTION TO ATTORNEY ANDREA FARAH’S
`DECLARATION, ADMINISTRATIVE MOTION TO STRIKE (DOC. 412), AND
`PURPORTED ORDER
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`I. Jaame, EL, a living man, appearing specially and not generally, do hereby solemnly affirm and
`declare under penalty of perjury as follows:
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`I. STANDING AND AUTHORITY
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`1. 'am a firsthand witness-claimant and the lawful representative for the JAAME AMUN RE
`* EL Estate, bringing forth an individual claim of $1,000,000.00 USD within this matter.
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`2. My claim is separate and distinct from the class petitioners represented by Attorney Andrea
`Farah, who serves as representative counsel for Lopez and her associates.
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`(U8}
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`. Attorney Andrea Farah did not file, establish, or perfect my individual claim. Said claim was
`sworn, entered, and affirmed by me directly. Therefore, she cannot move to strike it, nor
`presume representative authority over it.
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`II. LACK OF REPRESENTATIVE AUTHORITY
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`4. Statements of attorneys are not evidence. See 7rinsey v. Pagliaro, 229 F. Supp. 647, 649
`(E.D. Pa. 1964): “Statements by counsel are not evidence.”
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`5. No record exists establishing that Attorney Farah has entered into contract, retainer, or fiduciary
`obligation with myself or my Estate.
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`6. The Constitution prohibits compelled representation. The First Amendment guarantees
`freedom of petition to the courts, which necessarily includes the right to present one’s own
`claims without forced consolidation.
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`7. The Seventh Amendment preserves the right of trial by jury in suits at common law where the
`. value in controversy exceeds twenty dollars. My $1M claim is entitled to separate adjudication,
`and cannot be extinguished by motions from counsel representing other petitioners.
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`8. Further, Article I1I of the U.S. Constitution requires a true case or controversy. There is no
`controversy between Attorney Farah and myself, for she lacks any standing to contradict my
`direct, firsthand claim.
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`Case 4:19-cv-04577-JSW Document 418 Filed 10/06/25 Page 2 of 3
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`III. LEGAL SUPPORT
`9. In Sware v. The Board of Examiners, 350 U.S. 436 (1956), and Haine v. Kerner, 404 U.S. 519
`(1972). the Supreme Court recognized that pro se and individual claims must be considered,
`and cannot be dismissed merely for procedural or representative convenience.
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`10.The doctrine of “no one can speak for another without lawful agency” applies. Absent a
`grant of power of attorney or retainer, Attorney Farah cannot lawfully move to strike or alter my
`sworn claim.
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`11.As held in Johnson v. Zerbst, 304 U.S. 458 (1938), waiver of fundamental rights cannot be
`presumed but must be “knowing, intelligent, and voluntary.” I have given no such waiver.
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`IV. OBJECTION TO DOC. 412
`12.Attorney Farah’s September 25, 2025 Objection, Declaration, Administrative Motion to
`Strike (Doc. 412), and request for ORDER are void and without merit as they relate to my
`claim.
`13.Her filings constitute an overreach of representative authority and are hereby objected to,
`nunc pro tunc, on the record.
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`14.For avoidance of doubt: I affirm that [ am not a party to her representation, nor is she
`authorized to represent my Estate or its claims.
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`V. CONCLUSION AND RELIEF REQUESTED
`WHEREFORE, for the foregoing undeniable reasons, I respectfully pray this Honorable Court:
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`1. Disregard and deny Attorney Andrea Farah’s Declaration, Administrative Motion to Strike
`(Doc. 412), and any resulting ORDER, insofar as they purport to affect or extinguish my
`individual $1,000,000 claim. :
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`2. Acknowledge and preserve my separate claim as properly before this Court, immune from
`unauthorized interference by co-petitioner’s counsel.
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`3. Grant such further relief as this Court deems just and proper under the Constitution and
`governing case law.
`AFFIRMATION
`INDIVIDUAL ACKNOWLEDGMENT
`Pursuant to 49 CFR §1177.3
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`State of Connecticut
`County of Hartford
`Individual Form of Acknowledgement
`I. Jaame.EL, certify that | am the person described in and who executed the foregoing instrument and that |
`acknowledge that I executed the same as my free act and deed. | further declare under penalty of perjury
`“under the laws of Connecticut State, and the United States of America™ that the foregoing is true and correct.
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`xecut 3 Withgo
`] efi on 9/30/20245 r@’l‘b
`aame, E VTnett yRIOUSS L.,
`Witness-Claimant & Beneficiary of the JAAME AMUN RE EL Estate
`1131 Tolland Turnpike Suite O 106
`Manchester, Connecticut near 06042
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`706.843.7487
`Email: jaame.amunre.el@gmail.com
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`Case 4:19-cv-04577-JSW Document 418 Filed 10/06/25 Page 3 of 3
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`CERTIFICATE OF SERVICE
`[ Jaame. EL do hereby certify that I have hereby served a true and correct copy by mail and email on
`September 30", 2025 to:
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`Attention: Clerk's Office
`United States Courthouse
`450 Gelden Gate Avenue.
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`San Francisco. CA 94102-3489
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`Petitioners Attorney Contacts:
`vbriganti@lowey.com
`clevis@lowey.com
`mmaclean@lowey.com
`afarah@lowey.com
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`ENCLOSED ARE THE FOLLOWING DOCUMENTS:
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`1. AFFIDAVIT OBJECTION TO ATTORNEY ANDREA FARAH’S DECLARATION. ADMINISTRATIVE MOTION TO
`STRIKE (DOC. 412), AND PURPORTED ORDER I page
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`Wt epe
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