Scribd Logo
Upload

Welcome to Scribd!

  • 79 views

    SBN CA: C, HGL-Q S.s:rul: Joe Navasci'r

    Uploaded by

    prendadocs
    This document is a declaration by Brett L. Gibbs, an attorney formerly with Prenda Law, regarding his representation of AF Holdings in a copyright infringement case. In the 3 sentence summary: Gibbs states that he was supervised by John Steele and Paul Hansmeier regarding AF Holdings litigation and received instructions from them. He clarifies details about interactions with Mark Lutz that were described in Lutz's affidavit. Gibbs also discusses learning about a potential issue with a signature on an assignment agreement and being assured by Steele and Hansmeier that it was valid.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd

    SBN CA: C, HGL-Q S.s:rul: Joe Navasci'r

    Uploaded by

    prendadocs
    79 views3 pages
    This document is a declaration by Brett L. Gibbs, an attorney formerly with Prenda Law, regarding his representation of AF Holdings in a copyright infringement case. In the 3 sentence summary: Gibbs states that he was supervised by John Steele and Paul Hansmeier regarding AF Holdings litigation and received instructions from them. He clarifies details about interactions with Mark Lutz that were described in Lutz's affidavit. Gibbs also discusses learning about a potential issue with a signature on an assignment agreement and being assured by Steele and Hansmeier that it was valid.

    Original Description:

    #prenda #prendafail

    Original Title

    104-4

    Copyright

    © Attribution Non-Commercial (BY-NC)

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This document is a declaration by Brett L. Gibbs, an attorney formerly with Prenda Law, regarding his representation of AF Holdings in a copyright infringement case. In the 3 sentence summary: Gibbs states that he was supervised by John Steele and Paul Hansmeier regarding AF Holdings litigation and received instructions from them. He clarifies details about interactions with Mark Lutz that were described in Lutz's affidavit. Gibbs also discusses learning about a potential issue with a signature on an assignment agreement and being assured by Steele and Hansmeier that it was valid.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    79 views3 pages

    SBN CA: C, HGL-Q S.s:rul: Joe Navasci'r

    Uploaded by

    prendadocs
    This document is a declaration by Brett L. Gibbs, an attorney formerly with Prenda Law, regarding his representation of AF Holdings in a copyright infringement case. In the 3 sentence summary: Gibbs states that he was supervised by John Steele and Paul Hansmeier regarding AF Holdings litigation and received instructions from them. He clarifies details about interactions with Mark Lutz that were described in Lutz's affidavit. Gibbs also discusses learning about a potential issue with a signature on an assignment agreement and being assured by Steele and Hansmeier that it was valid.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Case3:12-cv-02396-EMC Case3:12-cv-02396-EMC Document104-4 Document94 Filed07/02/13 Filed08/28/13 Page1 Page1 ofof 33

    Nicholas Ranallo, Attorney at l-aur sBN 275016 li7l Dogwood Way Iloulder Creek. CA 95006 llhone: (831) 70-l -401I f'ax: (831) 533 - 5073 l c,hgl-q rc-l-ls l m -q-l ll,s s.s:rul:
    r

    Altomey for Joe Navasci'r


    I INI'TED S'I'A'TES

    DISTRICT C-OURT FOR 'TIIf;]

    NORTHERN DISTRICT OF CALIFORNIA


    SAN FRANCISCO DIVISION

    AF T{OLDINGS. I,LC.

    Casc No. : 3 :12-cv -02]96-IiN4C DI.l(

    Plaintitl.
    \ifi.

    rl-ARAI'lON OIr BRII'|]' GIIJIIS

    .I()I' NAVASCN
    Del'endant

    t. I trnr an erttorney duly

    licensecl to practice in the State of Calilbrnia anci befbrc the

    l)istric

    Court trirr the Northem District of Califbrnia. 'l'his declaration is traseri on persona
    knouledge of thc matters set fbrth herein.

    ) I am tirrmerly "Of

    Counsel" tbr Prenda [-aw. lnc.

    in Califbrnia, iind rept'cscnted r\[

    tloldings in that capacity in the instant nratter, as well as multiple othc'r cases throughoir
    the state of Caliibnria until approxinrately l]ebruary, 2013.
    .).

    As noted in rny N4arch l l.2013, testimony belbre the Central llistr-ii:t oi-flaliiorniii in t
    nratter ol' Ingemrity 13 v. l)oe. al ail relevant limes

    was supervise,-1 by aliorne,vs .loh


    ,.:asc

    Steele and Paul Hansmeier with rcgard to AF [{oldings' litigation. ir;cluding this
    ), tt

    .lohn Steele and Paul f{ansmc:ier lvere thc altorneys who I was iniirrtlt:cl comnttttticuie

    :., i:.

    with clie:nts such as AIr Floldings. and provicled me *'ith inslrutclious attri guidc-iitri:
    ',vhich I rvas inlbnned. originated h'om these clienls" inclr-rding AF

    Illlilings.

    l)ec I a ra'. i

    on of Bre t t-

    "

    G,i

    bl-':;

    Case3:12-cv-02396-EMC Case3:12-cv-02396-EMC Document104-4 Document94 Filed07/02/13 Filed08/28/13 Page2 Page2 ofof 33

    4.

    I have reviewed the Affidavit of Mark [.utz filed in this

    case on Ma-v-' 13.201-] (Doc


    para-eraph

    #80). I bclieve thal the inlbrmation

    provided

    in the fifth

    of'that alfidavi

    regarding tny interactions with Mr. i,utz is not an accurate description of thr-rsc events.

    tlid not "from time to time" send certilicates for Mr. I-utz to sign on bchal{'ol'the
    Marsh

    Sal

    l'rust. I did not have

    the alleged conversations rvith lvlr.

    Lutz. In

    lac1.

    I did no

    knorv that Mark Lulz was directly affiliatecl with these companics. as an owlter
    otherrvise. until months afler frling the ,A,DR Certification in this casc.
    5.

    Instead. I rvas specifically tolcl b5, iVlr. I-lansmeier that Salt Marsh u'as 1he r)u,ner

    crf-

    Holdings, antl that he. Salt Marsh. had reacl and tmderstood thc'AI)l( handbook"

    ancl

    cor-rlci

    go aheacl and filc the ADR Certification with the electronic signaturr' of Sal

    Marsh. Again, I never spoke with Salt Marsh directly. Through nrv con\;ersalion wit
    Ir,{r. l-lansnteier.

    I was under the intpression that the Salt Marsh was an inrlir,iclual

    r.vhr

    had

    in fact conrplied with the Local Rule and that his origin:rl siunafure exislecl

    on

    drlcutnent that rvas being held by rny then-ernployer. Prencla [,au'" information, I proceeded to file the AI)R Certilication on that basis.

    [r:c. (]ivcn tl
    thirt

    6. After I filed this case, I


    t:
    )
    i'j

    learned througlr a separate case

    flleti iri

    ir'tinnesr.rla

    assignment agrecment may have been invaljcl because there u'ers a <lispute r,r'hethcr

    signature orr the agreemenl was

    in fact fbrged.

    Once alcrtcd trr lhis.

    inrmecliately

    discussed this matter with .lohn Steelc and Paul I lansmeier. fhcr, rs:,iu'cd nrc tlrat it. rv
    .'
    r-l

    a valid signature. thal the allegatir:ns \verc rnerc ''conspiraci' thr:ories," and that

    shor.r!t

    ,'' l

    have rro croncern in continuing to plosecute this and other AF Holdinss' cases. I believe was diligent in rny factualand lc-gal investigation of this lnatter.

    '/) a

    I tleclare under penalfy of perjurv under thc laws of the State of Califrrrnia fhat thc
    firregoing is true and correct. t'his declaration is executed on

    this Y1U"t of June 2013,

    ", Uill

    Volk

    California.

    Case3:12-cv-02396-EMC Case3:12-cv-02396-EMC Document104-4 Document94 Filed07/02/13 Filed08/28/13 Page3 Page3 ofof 33

    2
    ?

    Brett L. Gibbs, Esq. 38 Miller Ave.,#263

    Mill Valley,CA9494l

    5 6

    't
    B

    10
    11

    12
    13
    _t

    .l

    CERTIFICATE OF SERVICE
    I HEREBY CERTIFY that on this day of June,2013, a true and correct copy of the foregoing was filed with the Clerk -of the Court using the CM/ECF system and served on all,of those parties receiving notification through the CM/ECF system.

    1"5

    L6
    1.1

    1B

    19

    lsl By: Nicholas Ranallo

    20

    )'i 24

    25
    ?.t,

    2't
    L6

    Declaration of Brett 1,. Gibbs

    You might also like