Xcentric Ventures, LLC et al v. Stanley et al

Filing 82

Notice re of Filing Declaration of Thomas Zeeh Regarding Attempted Service of Process Upon Defendant William "Bill" Stanley by Xcentric Ventures, LLC(an Arizona Corporation), Ed Magedson(an individual) (Attachments: # 1 Exhibit 1)(Speth, Maria)

Xcentric Ventures, LLC et al v. Stanley et al

Doc. 82

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JABURG & WILK, P.C. ATTORNEYS AT LAW 3200 NORTH CENTRAL AVENUE SUITE 2000 PHOENIX, ARIZONA 85012

Kraig J. Marton, #003816 [e-mail] Maria Crimi Speth, #012574 [e-mail] Adam S. Kunz, #018827 [e-mail] Laura A. Rogal, #025159 [e-mail] JABURG & WILK, P.C. 3200 North Central Avenue, Suite 2000 Phoenix, Arizona 85012 [phone] Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA XCENTRIC VENTURES, LLC, an Arizona corporation, d/b/a "RIPOFFREPORT.COM"; ED MAGEDSON, an individual Plaintiffs, v. WILLIAM "BILL" STANLEY, an individual; WILLIAM "BILL" STANLEY d/b/a DEFAMATION ACTION.COM; WILLIAM "BILL" STANLEY d/b/a COMPLAINTREMOVER.COM; WILLIAM "BILL" STANLEY aka JIM RICKSON; WILLIAM "BILL" STANLEY aka MATT JOHNSON; ROBERT RUSSO, an individual; ROBERT RUSSO d/b/a COMPLAINTREMOVER.COM; ROBERT RUSSO d/b/a DEFENDMYNAME.COM; ROBERT RUSSO d/b/a QED MEDIA GROUP, L.L.C.; QED MEDIA GROUP, L.L.C.; QED MEDIA GROUP, L.L.C. d/b/a DEFENDMYNAME.COM; QED MEDIA GROUP, L.L.C. d/b/a COMPLAINTREMOVER.COM; DEFAMATION ACTION LEAGUE, an unincorporated association; and INTERNET DEFAMATION LEAGUE, an unincorporated association; Defendants.
10297-14/LAR/LAR/614920_v1

Case No: 2:07-CV-00954-NVW NOTICE OF FILING DECLARATION OF THOMAS ZEEH REGARDING ATTEMPTED SERVICE OF PROCESS UPON DEFENDANT WILLIAM "BILL" STANLEY

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Case 2:07-cv-00954-NVW

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JABURG & WILK, P.C. ATTORNEYS AT LAW 3200 NORTH CENTRAL AVENUE SUITE 2000 PHOENIX, ARIZONA 85012

Plaintiffs Xcentric Ventures, LLC and Ed Magedson ("Plaintiffs"), through counsel undersigned, hereby give notice that they are filing with the Court the Declaration of Thomas Zeeh (the "Declaration") regarding attempted service of process upon Defendant Stanley, as referenced in Plaintiffs' Motion for Alternative Service Upon Defendant Stanley, Document No. 72, filed with the Court on September 27, 2007. At the time of filing the Motion, the Declaration had not yet been translated. Plaintiffs have since received an official translation of the Declaration, and therefore the Declaration and translation are attached hereto as Exhibit 1. The Declaration is in support of the following statement made in Plaintiffs' Motion for Alternative Service Upon Defendant Stanley: William Stanley lists an Austria address at 8 Redetsky Strasse, Klagenfurt in all of his domain name registrations. He has sent emails and made verbal statements that he is living in Austria and not subject to the laws of the United States. However, an investigator located in Austria went to Stanley's Austria address and also contacted the owner of that property, Alfred Schurz. The investigator has reported back that Stanley had previously lived at the 8 Redetsky Strasse address, but left for America "several weeks ago". Exhibit "1", Affidavit and translation to be filed at a later date. Although Plaintiffs are aware that the Court has granted Plaintiffs' Motion for Alternative Service, Plaintiffs had represented to the Court that the Declaration would be filed upon receipt and translation. DATED this 22nd day of October, 2007.

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JABURG & WILK, P.C.

s/Maria Crimi Speth Maria Crimi Speth Attorneys for Plaintiffs 2
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JABURG & WILK, P.C. ATTORNEYS AT LAW 3200 NORTH CENTRAL AVENUE SUITE 2000 PHOENIX, ARIZONA 85012

Certificate of Service I hereby certify that on October 22, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing, and for transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Teresa Kay Anderson Snell & Wilmer LLP One Arizona Center 400 E Van Buren Phoenix, AZ 85004 Michael Kent Dana Snell & Wilmer LLP One Arizona Center 400 E Van Buren Phoenix, AZ 85004-0001 With a COPY of the foregoing emailed on this 22nd day of October, 2007, to: William "Bill" Stanley [e-mail] [e-mail] With a COPY of the foregoing hand delivered on the 23rd day of October, 2007, to: Honorable Neil V Wake United States District Court District of Arizona

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s/Debra Gower

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