Professional Documents
Culture Documents
FL 33139 161 N. Clark St. Suite 3200, Chicago IL 60601 Springates East Government Road Charlestown, Nevis Livewire Holdings, LLC 2100 M St. NW Suite 170-417 Washington DC 200037 2135 CityGate Ln, Suite 300 Naperville, IL 60563 Steele, John IL 6292158 Mooney Hansmeier, Paul MN 0387795 Hansmeier, Peter Cooper, Alan Lutz, Mark Sargeant, Aisha Steele Hansmeier, LLC Trust Alpha Law Firm
AF AF Holdings LLC
Documents Referenced
PH_Dep PH Dec 09/02/1010 Pfister Dec Peter Dec Merkel Aff Merkel complaint Coopliant Nguyen Trib 03/10 Doe OSC 26(f) 2.14.12 13-L-15 Pecadeso Sundarrajan Peter Decl 6.6.2011 Trib 1.30.2013 Gibbs Dec Trans0402 Trans0311 Gibbs Dec 12.21.12 Gibbs11.18.2012 SteeleAff12.20.2012 MerkelTran1.25.13 Mar11 Lutz 420 Phil Handymeyer Depo PH Declaration 09/02/1010 Pfister Declaration 02/02/2011 Peter Declaration 01/31/2012 Merkel Affadavit 01/25/2013 Merkel Complaint Hacking 10/17/2012 Cooper Complaint 1/23/2103 Nguyen hearing 11/27/2011 Star Tribune 03/10/2013 Doe OSC response 2.19.13 26(f) Report 2.14.13, AFH v Does 1-135 LW Systems re Hubbard (hacking) AF v Pedadeso 2.30.2013 order AF v Sundarrajan declaration 10.30.2012 Peter Declaration 06/06/2011 Jason Sweet Declaration 1.30.2013 Gibbs' 3.1.2013 Declaration Transcript 4.2.2013 hearing Transcript 3.11.2013 hearing Gibbs' 12.21.2012 Declaration Gibbs' 11.18.2012 letter to judge Scriven Steele Affidavit in Sunlust v Nguyen Transcript of Merkel Hearing 1.25.2012 Transcript of March 11 hearing Declaration of Mark Lutz - no date
ed: who else imagines Steele, his Sister, Saltmarsh, and a bunch of Alan Coopers living in an Apartment running notissues.com?
Steele Law opens 2008 Steele Aff 12.20.2012 Steele Law filed w/ IL Sec of State 5.7.2007 Steele Aff 12.20.2012
Torres' cut is 75% Torres does not know 6 Nguyen Lutz 15 Nguyen
Steele is not involved with Prenda nor this case 12 Nguyen Prenda told court they are not involved in this case 4 Nguyen Lived with Steele's sister 144 PH_dep PH met Steel in Law school 144 PH_dep
Address in AZ is same VPR Inc 14 Doe OSC Jayme Steele 14 Doe OSC
Address in AZ is same notissues.com 14 Doe OSC AC is registrant, but Steele email. 14 Doe OSC
6681 Forensics Prenda Law Duffy, Paul IL 6210496 Anti-Piracy Law Group Guava, LLC Lie, he is in LA, id Sunny Leone is president of Sunlust 17 Nguyen
Gets $1000 to appear Torres was contacted in court 15 Nguyen Does not by Gibbs to be local know Duffy consel 5 Nguyen 11 Nguyen Lutz is corporate rep Lutz not authorized J Torres, FL counsel of Sunlust, not an to bind Sunlust for Sunlust 2 Nguyen officer 14 Nguyen 14 Nguyen Also rep for Hard Drive and Guava 17 Nguyen Lutz asked TSL to form AF Holdings AF 74 PH_dep Mark "No coat No tie" Lutz 3 Nguyen
deputized by AS 147PH_dep
Media Copyright Group, LLC David Pfister Spencer Merkel Trina Morrison Michael Dugas Ingenuity 13, LLC Johnathan Torres Sunny Leone Salt Marsh LiveWire daniel weber
Sirh-Ryun Stella Wi Dugas Adam Urbanczyk Steel Law Firm
D Weber is DW is out of the principal country, id 12 Doe OSC Documents reviewed for depo prep: certificate of formation articles of organization doc that listed Aisha Sargeant as organizer 59 PH_dep Pietz identifies three people associated with a trust in Nevis: Settler Beneficiary Lutz's childern are Trustee 69 PH_dep benficiaries Lutz420
Anthony Saltmarsh also corp rep 143 PH_dep ML founder Livewire Doe OSC 20
given the role by AS at the direction of ML 141 PH_dep ML given ths role by AS 141 PH_dep ML manages 20 attys, 50 cases 141 PH_dep ML worked for Steele. PH never delegated anything to him 132 PH_dep S|H ML worked for Steele Hansmeier 130 PH_dep
AF
ML is only person at AFH with authority to settle a case 208 PH_dep Attys across the country can settle 208 PH_dep ML delegates to attys and contractors like 6681 194 PH_dep Prenda law helps Lutz decide who to sue 211 PH_dep Of Counsel for Prenda Gibbs Dec 12.21.12 "Carl" worked with Gibbsmaybe auth to use ECF Mar11 106 and in-house for AF Mar11 105 also in-house for Guava and Livewire Doe OSC 18 Of Counsel to S|H. Hired 2.14.2011 Gibbs Dec
switch to Prenda Nov 2011
Lutz asked AS to form AF Holdings 74 PH_dep PH does not know who paid AS to create the trust 71 PH_dep
AF
Gibbs told someone that negotiations go through him Mar11 94 Gibbs was secratary for local counsel in other states Mar11 109
Structure at S|H & Prenda Instructions & Guidelines Gibbs reported to Steel and PH Gibbs Dec Report Steele, PH, and Lutz all work for Livewire Gibbs Dec
created by Aisha Sargeant 40 PH_dep membership interests in AFH are held in trust Lutz420 owned by Salt Marsh 45 PH_dep owned by Salt Marsh P_ex100 PH_dep
BU T. ..
. . . o t s i e rol
Alan Cooper corporate AF representative of AFH 121 PH_dep Paul Godfread represents Cooper 122 PH_dep several dozen 112 PH_dep
Heartbreaker
Plaintiffs and their titles AF Holdings LLC Popular Demand 8.9.2011 PA0001754383 (c) Heartbreaker assigned to AF Holdings LLC 12.20.2011
no accountant 198 PH_dep books are spreadsheets 198 PH_dep no way to determine revenue 200 PH_dep not very complicated 198 PH_dep
undefined beneficiary Livewire bought trust AFH the before Salt Marsh Owns the PH Dep AF Holdings wholly owns 28 Doe OSC 26(f) 2.14.12 40 PH_dep
Heartbreaker Digital, LLC is assignor 153 PH_dep Raymond Rogers assigns to assignee, signed by Cooper 125 PH_dep
Brett Gibbs inhouse for AFH 133 PH_dep AF Mooney denies knowledge Trib 03/10
one employee - Mark Lutz 127 PH_dep LLC organized under the laws of the Federation of St. Kitts & Nevis 55 PH_dep
ML asked Steele for a representative. Steele delivered Cooper 122 PH_dep Cooper sues Steele et al for identity theft Coopliant 6681 Forensics 162 PH_dep PH is not shareholder, officer, nor employee 162 PH_dep 6681 PH has a 6681 email 162 PH_dep Peter H is technician, and PH's brother 166 PH_dep uses software called "Alena" 174 PH_dep Alpha has never paid 6681 6681 206 PH_dep Prenda pays 6681 206 PH_dep
6681
Ingenuity 13, LLC A Peek Behind the Scenes at a Show PA0001802629 8.24.2012 Five Fan Favorites PA0001791654 5.29.2012 URL reg'ed 9/13/11 Timeline
Created 05/2011 proceeds of AF Holdings settlements 21 PH_dep most attorneys are paid on Steele is of counsel to generated aren't contingency 110 PH_dep Prenda 2.13.13 distributed to AF Steele no longer actively AF Holdings, but are settlement 18 Doe OSC Springates East practices law 11.27.02 Government Road 33% proceedings instead used to either Charlestown, Nevis 19 Nyugen 115 PH_dep Gibbs Dec go into pay for previously incurred expenses or held by the trust accounts If Alpha Law Firm attorneys to pay for future litigation wins $ goes into expenses. 81 PH_dep Anti-Piracy Law Group Mr. Steele has no right to Prenda account 88 PH_dep 95 PH_dep these trust accounts: 93 PH_dep Prenda Law 87 PH_dep Alpha has not withdrawn from Prenda Trust account 98 PH_dep Alpha has not received compensation Alpha has been from113 PH_dep reimbursed by 205 PH_dep Cathy in writes reimbursement checks 99 PH_dep Alpha has no employees 134 PH_dep Steele is not affiliated with Alpha 255 PH_dep Money has transferred out only for litigation expenses, nothing else 106 PH_dep CA and IL. Paul Duffy is principal 211 PH_dep Paul Duffy is principal 211 PH_dep Anderson & Associates 91 PH_dep PH has no right to these trust accounts: 94 PH_dep
negotiated by Lutz and Rogers, not 125 PH_dep Steele 155 PH_dep after 2011 provided IP addresses to S|H Started 10/7/10 Started 6/21/10 176 PH_dep timeline MCGIP Inc. timeline 169 PH_dep Media Copyright Group 169 PH_dep PH was organizer and technician 171 PH_dep David Pfister technician Pfister dec Peter H is technician Peter Decl 6.6.2011 Peter H is Manager http:// mblsportal.sos.s tate.mn.us signatures look a lot alike 235 PH_dep Ex109 performs tech services 171 PH_dep
Mooney listed as sole organizer Trib 03/10 PH not familiar 170 PH_dep PH was orqanizer 170 PH_dep held copyrights and produce content 250 PH_dep
Dissolving
S|H filed notice of dissolution with Sec of State 256 PH_dep 1/13/2012 Trib 1.30.2013
incorporated MN 9.9.2010 Trib 1.30.2013 Appeared in Pacific Century on 2/24/2012 Trib 1.30.2013
No formal affiliation 256 PH_dep PH never worked for Prenda 130 PH_dep
Prenda filed substitution of counsel in S|H cases across the board 257 PH_dep PH had no formal affiliation with Prenda 257 PH_dep Steele handled the money that was in the S|H trust account 257 PH_dep Gibbs was of counsel to S|H 258 PH_dep
Duffy & Steele known each other since law school Steele Aff 12.20.2012
explos
ion
PH and AM met while PH was at a firm 247 PH_dep Alan "Mony" signed false verification Doe OSC 15
gue n o t e ?
work title Popular Demand 259 PH_dep ISPs are world-class 154 PH_dep Private regaring IPinvestigators, identification yes 215 189 PH_dep downloads files and compares them to Work to ensure substantial similarity. Stores data in central database. (MCG) PH Dec 09/02/1010 Pfister dec
ed: not sure if this is the case Guava sued Spencer Merkel. OR resident sued in MN Merkel aff 27-CV-12-20976 Based on Prenda advice Merkel aff Duffy signed Prenda threat letter Merkel aff
Michael Dugas worked at Prenda 136 PH_dep Dugas attorney through Alpha for Guava Merkel Complaint
Michael Dugas worked for AFH but not as employee 135 PH_dep
f slip o
th
Atty for Alpha but used wefightpiracy email address Merkel Complaint
Spencer rep'ed by Trina Morrison Merkel aff Spencer agreed to be sued and provide his BT logs in exchange for dismissal Merkel aff
Spencer called Prenda and talked to "Michael" who was working for Alpha Dugas? Merkel Aff
Morrison and Dugas are friends and went to U of MN Law together MerkelTran1.25.13
Sirh-Ryun Stella Wi Dugas address is Alpha mncourts.gov Paul says she did not work for Alpha. 135 PH_dep SRSWD worked for LiveWire Holdings LLC LinkedIn via SDJ SRSWD was an attorney with Prenda Sundarrajan SRSWD an AF AF attorney Pecadeso LiveWire is in a UPS store in DC LinkedIn via SDJ
married LiveWire "Systems" in Hubbard case 13-L-15 Hubbard defense atty is Adam Urbanczyk SDJ 2013/01/31
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