The following information is an HTML version of the contract signed by Timothy P. Connaghan, then president of The Amalgamated Order of Real Bearded Santas.

This document, signed by Timothy P. Connaghan, and notarized by his friend, and fellow Santa Claus, and then member of The Amalgamated Order of Real Bearded Santas, Mr. Bob Callahan, states that the domain name www.AORBSantas.com is the sole property of The Amalgamated Order of Real Bearded Santas. The website, www.AORBSantas.com was created, developed and published by The Amalgamated Order of Real Bearded Santas.

To view a screen shot of the actual pages, click here - Page 13, Page 14, Page 15

(page 13) KNOW ALL MEN BY THESE PRESENTS: That in consideration for the payment of ONE Dollar ($1.00) and other good and valuable consideration the (the receipt and sufficiency of which are hereby acknowledged), the undersigned, Amalgamated Order of Real Bearded Santas ("Owner"), hereby sells, grants, assigns and sets over unto Bruce Nash Entertainment (hereinafter referred to as "Producer"), and Producer's representatives, successors and assigns forever, any and all media and related production rights and interests, including without limitation, all motion picture rights, television motion picture and other television and all allied and ancillary rights, sequel and remake rights, music and music publishing rights, soundtrack album and other soundtrack exploitation rights, electronic media and interactive rights, streaming rights, wireless transmission rights, internet rights, merchandising rights, live state rights, radio rights, theme park rights and promotional and advertising rights, but subject to certain "Reserved Rights", throughout the Universe, in perpetuity, in and to the materials identified in Exhibit A of the "Agreement" (defined below) to the extent each item identified in Exhibit A relates in anyway to Santa Claus convention, Santa Claus schools, the training of Santa Clauses, the business of Santa Claus or the story of Santa Claus, (which together with the titles, themes, contents and characters and other versions thereof is hereinafter called the "Property"), and in and to the copyright of the Property and all renewals and extensions of such copyright, and in and to the motion picture project based thereon (the "Picture"). This Assignment is subject to the terms and conditions of that certain Agreement between the Owner and Producer dated as of February 2, 2007. Owner shall execute, but not date, this Assignment which shall be held in trust by Producer. If Producer exercises the option pursuant to the Agreement then Producer shall date this Assignment as of the date of the Producer's exercise of the option, if ever. Producer is also hereby empowered to bring, prosecute, defend and appear in suits, actions and proceedings of any nature under or concerning all copyrights in and to the Property and/or the Picture, and all renewals thereof, or concerning any infringement thereof, or interference with any of the rights hereby granted under said copyrights or renewals thereof, in its own name or in the name of Owner or other copyright proprietor, but at the expense of Producer, and, at its option, Producer may join such copyright proprietor and/or Owner as a party plaintiff or defendant in any such suit, action or proceeding. IN WITNESS WHEREOF, the undersigned has executed this Assignment as of the 23rd day of March, 2007. Amalgamated Order of Real Bearded Santas By: Timothy P. Connaghan Its: President - AORBS

(page 14) COUNTY OF Orange STATE OF California On this 23 day of March 2007, before me Bob Callahan, Notary Public personally appeared Timothy P. Connaghan personally known to me whose name is subscribed to this instrument, and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument. WITNESS my hand and official seal. Bob Callahan (signature) Notary Public Bob Callahan Commission #1617587 Notary Public - California Orange County My Comm. Expires Nov 1 2009

(page 15) Exhibit A The following items are the sole property of the Amalgamated Order of Real Bearded Santas (Owner), were created, developed and published by the Owner and will be loaned or made available to the Producer for the purposes as described in the Option Agreement. The materials identified in the Exhibit, together with the titles, themes, contents and characters and other versions thereof is hereinafter called the "Property" 1. Website - www.discoversanta.com - Over 100 web pages with Convention descriptions, agendas, workshop details, newsroom with media clippings, newsletter file with weekly newsletters. Media releases and promotional materials, registration pages and forms, etc. 2. Website - www.aorbsantas.com - The official web site of Owner containing information and a brief photo history on the association, information and a brief photo history on the association, membership rules, regulations and policies; Membership Application information. A list of Officers and Directors; and brief information on the 2006 and 2008 conventions. 3. Access to the Electronic newsletters and promotional emails related to the 2006 convention. (Included in item 1 above) 4. Access to the membership discussion site at MSN.com: http://groups.msn.com/AORBSRealSantas/general.msnw 5. Discover Santa - Program book from 2006 Convention

Inconsistent to what Timothy P. Connaghan already swore to in this signed, notarized legal document, (which is a contractural agreement, between Bruce Nash Entertainment and The Amalgamated Order of Real Bearded Santas) on January 24 2008, Mr. Timothy P. Connaghan using his previous position of trust, as Adminstrative Contact on the domain name AORBSantas.com, transfered the ownership of AORBSantas.com from The Amalgamated Order of Real Bearded Santas, to Mr. Tom Hartsfield, without the foreknowledge and consent of the Board of Directors of The Amalgamated Order of Real Bearded Santas.

Timothy P. Connaghan then posted on the yahoo group message board known as "SantaTalk" that Mr. Hartsfield had "resumed ownership". He also publicly posted the following lie; "The name Amalgamated Order of Real Bearded Santas was created by the Founder, Santa Tom Hartsfield." (we are calling it a lie, because it is documented as such by Nash Entertainment Contract).

Mr. Timothy P. Connaghan has publicly posted information he knew and knows to be untrue. Mr. Timothy P. Connaghan also willfully interfered with the provisions of a contract that he signed, this signature was witnessed and attested to by Mr. Bob Callahan, California Notary Public, Commission #1617587.

As of this date 10/17/2008, the domain name which Timothy P. Connaghan swore to Bruce Nash Entertainment as being the sole property of The Amalgamated Order of Real Bearded Santas is currently hosted without permission of the Board of Directors of The Amalgamated Order of Real Bearded Santas, by a Mr. Ric Erwin of Laguna Niguel CA.

Mr. Ric Erwin was put out of membership by a vote of the Board of Directors of the Amalgamated Order of Real Bearded Santas, (as was Timothy P. Connaghan) for conduct not in keeping with the standards and goals of The Amalgamated Order of Real Bearded Santas. After his removal as a member, Ric Erwin published the current content (as of 10/17/2008) on AORBSantas.com in retaliation for this removal from our organization.

Unfortunately, Mr. Ric Erwin's conduct at the "Meet and Greet" with the Board of Directors, made it necessary to have him forcebly removed by three security guards of Knott's Berry Farm Hotel. Since Mr. Erwin felt humiliated, as a result of his removal due to his conduct, he decided to retaliate and wreck havoc upon the organization, and specifically its directors, by posting lies, and other false accusations against the members of the Board of Directors on the misappropriated website, www.AORBSantas.com.

http://groups.yahoo.com/group/SantaTalk/message/858

From Santa53@... Thu Jan 24 10:07:00 2008 Return-Path: X-Sender: Santa53@... X-Apparently-To: SantaTalk@yahoogroups.com X-Received: (qmail 16369 invoked from network); 24 Jan 2008 18:07:00 -0000 X-Received: from unknown (66.218.67.95) by m46.grp.scd.yahoo.com with QMQP; 24 Jan 2008 18:07:00 -0000 X-Received: from unknown (HELO n13c.bullet.sp1.yahoo.com) (69.147.64.114) by mta16.grp.scd.yahoo.com with SMTP; 24 Jan 2008 18:07:00 -0000 X-Received: from [216.252.122.218] by n13.bullet.sp1.yahoo.com with NNFMP; 24 Jan 2008 18:07:00 -0000 X-Received: from [66.218.69.2] by t3.bullet.sp1.yahoo.com with NNFMP; 24 Jan 2008 18:07:00 -0000 X-Received: from [66.218.67.201] by t2.bullet.scd.yahoo.com with NNFMP; 24 Jan 2008 18:07:00 -0000 Date: Thu, 24 Jan 2008 18:06:59 -0000 To: SantaTalk@yahoogroups.com Message-ID: User-Agent: eGroups-EW/0.82 MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="1-5290884988-7088475975=:3" X-Mailer: Yahoo Groups Message Poster X-Yahoo-Newman-Property: groups-compose X-Originating-IP: 69.147.64.114 X-eGroups-Msg-Info: 1:6:0:0:0 X-Yahoo-Post-IP: 75.4.202.137 From: "Timothy Connaghan" Subject: Ownership of the AORBS web site X-Yahoo-Group-Post: member; u=70081521; y=bdfhk9PRCues0QAITSefSLtNdasxU0Txpcj0593wJGatMmAmIIl856fUP8dM4g X-Yahoo-Profile: tconnaghan --1-5290884988-7088475975=:3 Content-Type: text/plain; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable Ownership of the AORBS web site I have read this morning's posts and wish to respond. The name Amalgamated Order of Real Bearded Santas was created by the Founder, Santa Tom Hartsfield. The AORBS web address and web site was purchased, created and registered by none other than Tom Hartsfield. Yesterday, he resumed ownership and registration of the name and address. I spoke with him this morning and he does not want any of the artwork or items that the interim board has created or posted and will work with their web master in making sure they are available for whatever web site they wish to create. On another note, there is a second web site, DiscoverSanta.com. This website was created and registered by me for the 2006 convention. It was purchased online in September of 2005 and paid for by me with one of my credit cards. I have been the registered owner since that time. However, I did reimburse myself for the cost of the web site, with proceeds from the convention. As those monies came from the members, I would never assume that the web address is mine, nor want to take it away from the Association. Someone should take whatever steps necessary to secure this site as a property of the AORBS. Tom Hartsfield, created the name Amalgamated Order of Real Bearded Santas. He also created the web address, purchased it, registered it and put it up on the World Wide Web ten years ago. If you have questions, I would suggest that you contact him as to what his plans are. Santa Tim Connaghan

As stated in our history page, Tom Hartsfield, along with nine other Santas founded, the Amalgamated Order of Real Bearded Santas. Two of the orginal ten founders serve on the current Board of Directors of The Amalgamated Order of Real Bearded Santas; Frank Turner and Leonard Ray. A few years later, Tom Hartsfield, tried to sell the group to Tim Connaghan for $2,000.00. For whatever reason at the time, Tim Connaghan did not purchase the group. Hartsfield then gave the group to Tim Connaghan. Connaghan took the group and finally made the organization a legal entity when he incorporated it as "The Amalgamated Order of Real Bearded Santas Inc." in January 2007. (AORBS History, the summation of the history of our group, a page that Tom Hartsfield himself, stated as being correct.)

Under the leadership of President Nicholas Trolli, it became and remains a legal Non Profit Corporation, the group does not belong to any one individual. It did not belong to Connaghan, and it did not belong to Hartsfield. At the time Connaghan gave away the resource known as www.AORBSantas.com to Hartsfield, it was not his to give. The domain name, as stated in the notarized legal document, signed by Connaghan is the sole property of The Amalgamated Order of Real Bearded Santas.

The Board of Directors have repeatedly asked and are now taking legal steps to demand that Ric Erwin, Tom Hartsfield, Tim Connaghan and John Degel terminate the libelous content on www.AORBSantas.com and return the stolen domain name to its rightful and sole owner, namely; The Amalgamated Order of Real Bearded Santas. We are also demanding that the content at www.ricnvic.com/aorbs, the actual server/website that the domain name www.AORBSantas.com is pointing to, be removed from the internet, and a retraction as well as an apology to AORBS be published in its place.

The Board of Directors of The Amalgamated Order of Real Bearded Santas