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William McPike State Bar #95869 257 East Bellevue Road, # 188 Atwater, CA 95301 (559) 841-3366 Email: mcpike@psnw.com Attorney for Acacia Corporate Management, LLC Michael Scott Ioane, & Mariposa Holding Inc.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA STEVEN BOOTH and LOUISE BOOTH, Plaintiffs, v. MICHAEL SCOTT IOANE, ACACIA CORPORATE MANAGEMENT LLC, , Does 1-25,inclusive; and All Persons Unknown Claiming Any Legal or Equitable Right, Title, Estate, Lien or Interest in the Property Described in the Complaint Adverse to Plaintiffs' Title or Any Cloud) Upon Plaintiffs' Title Thereto, Named Herein as Does 26 through 50, inclusive, Case No. 1:12-CV-171 AWI GSA DEFENDANTS OBJECTION TO OPPOSITION BY UNITED STATES TO MOTION TO DISMISS Date: May 21, 2012 Time: 1:30 p.m. Place: Courtroom 2, 8th Floor Judge: Hon. Anthony W. Ishii

Defendants. _______________________________ AND RELATED CROSS-ACTION COMES NOW defendants, ACACIA CORPORATE MANAGEMENT LLC and Michael Scott Ioane, by and through their counsel to object and request that the court strike the opposition filed by the United States to the motion to dismiss state court removed case, filed by Defendants ACACIA CORPORATE MANAGEMENT LLC, and Michael Scott Ioane and directed at the plaintiffs Dr. Steven Booth and Mrs. Booth. The objection and request to strike is based on the following grounds:

OBJECTION TO OPPOSITION BY UNITED STATES TO MOTION TO DISMISS

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First, Although the United States has been informed of Defendants motion through electronic means by the clerks office, it has no standing to oppose Defendants motion since they are not defendants in this action, and are not named by Plaintiffs as defendants in this action. Second, Defendants motion is directed at the Plaintiffs in this action, not the United States. For all the foregoing reasons and those not mentioned we request that the court sustain our objection and strike the filing. If the court believes we need to more fully brief this issue, we then ask for continuance to do so. Respectfully submitted May 15, 2012. By:/s/ William McPike /s/ William McPike Certificate of Service It is hereby certified that on May15, 2012, I electronically filed the foregoing: 1) 2) 3) 4) 5) Reply to Plaintiff Opposition to Dismiss, removed state court case Judicial Notice in Support of Reply Declaration of Ioane in Support of Reply Objection and request to strike to united states opposition to motion to dismiss Objection and request to strike reply by plaintiff to US opposition to motion to dismiss. With the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: G Patrick Jennings,Trial Attorney Tax Division,US Dept of Justice,P.O. Box 683,Ben Franklin Station,Washington, D.C. 20044-0683And Randolf Krbechek, 9477 N. Fort Washington Road, Suite 104,Fresno, CA 93730

By:/s/ William McPike /s/ William McPike

OBJECTION TO OPPOSITION BY UNITED STATES TO MOTION TO DISMISS