Asia Economic Institute et al v. Xcentric Ventures LLC et al

Filing 87

EX PARTE APPLICATION to Continue the determination of, or denying, Defendants' Motion for Summary Judgment from July 12, 2010 to At the Court's discretion Re: MOTION for Summary Judgment as to Entire Case 40 , EX PARTE APPLICATION to Enforce Order to Compel Continued Deposition of Defendant Edward Magedson, EX PARTE APPLICATION for Sanctions Local Rule 83.7, Local Rule 37-4, and this Court's inherent authority filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 1 to Declaration of Lisa J. Borodkin, # 2 Exhibit 2 to Declaration of Lisa J. Borodkin, # 3 Exhibit 3 to Declaration of Lisa J. Borodkin, # 4 Exhibit 4 to Declaration of Lisa J. Borodkin, # 5 Exhibit 5 to Declaration of Lisa J. Borodkin, # 6 Exhibit 6 to Declaration of Lisa J. Borodkin, # 7 Exhibit 7 to Declaration of Lisa J. Borodkin, # 8 Exhibit 8 to Declaration of Lisa J. Borodkin, # 9 Exhibit 9 to Declaration of Lisa J. Borodkin, # 10 Exhibit 10 to Declaration of Lisa J. Borodkin, # 11 Exhibit 11 to Declaration of Lisa J. Borodkin, # 12 Exhibit 12 to Declaration of Lisa J. Borodkin, # 13 Exhibit 13 to Declaration of Lisa J. Borodkin, # 14 Exhibit 14 to Declaration of Lisa J. Borodkin, # 15 Exhibit 15 to Declaration of Lisa J. Borodkin, # 16 Exhibit 16 to Declaration of Lisa J. Borodkin, # 17 Exhibit 17 to Declaration of Lisa J. Borodkin, # 18 Exhibit 18 to Declaration of Lisa J. Borodkin, # 19 Exhibit 19 to Declaration of Lisa J. Borodkin, # 20 Exhibit 20 to Declaration of Lisa J. Borodkin, # 21 Exhibit 21 to Declaration of Lisa J. Borodkin, # 22 Exhibit 22 to Declaration of Lisa J. Borodkin, # 23 Exhibit 23 to Declaration of Lisa J. Borodkin, # 24 Exhibit 24 to Declaration of Lisa J. Borodkin, # 25 Exhibit 25 to Declaration of Lisa J. Borodkin, # 26 Exhibit 26 to Declaration of Lisa J. Borodkin, # 27 Exhibit 27 to Declaration of Lisa J. Borodkin, # 28 Exhibit 28 to Declaration of Lisa J. Borodkin, # 29 Exhibit 29 to Declaration of Lisa J. Borodkin, # 30 Exhibit 30 to Declaration of Lisa J. Borodkin, # 31 Exhibit 31 to Declaration of Lisa J. Borodkin, # 32 Exhibit 32 to Declaration of Lisa J. Borodkin, # 33 Exhibit 33 to Declaration of Lisa J. Borodkin, # 34 Exhibit 34 to Declaration of Lisa J. Borodkin, # 35 Exhibit 35 to Declaration of Lisa J. Borodkin, # 36 Exhibit 36 to Declaration of Lisa J. Borodkin, # 37 Exhibit 37 to Declaration of Lisa J. Borodkin)(Borodkin, Lisa)

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Gmaila Economic Institute etDavidXcentric Ventures LLC et al Asi - Fwd: Hi Smitty....from al v. https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt87 earch=st... Doc. &s Att. 32 Lisa Borodkin <lborodkin@gmail.com> Fwd: Hi Smitty....from David Seeknpeace@aol.com <Seeknpeace@aol.com> To: lborodkin@gmail.com Sat, Jul 3, 2010 at 2:09 PM From: Fee44@aol.com To: seeknpeace@aol.com Sent: 7/3/2010 2:53:12 P.M. Eastern Daylight Time Subj: Fwd: Hi Smitty....from David From: fee44@aol.com To: david@ripoffreport.com Sent: 1/20/2010 3:20:25 P.M. Eastern Daylight Time Subj: Re: Hi Smitty....from David You know David, you have left me very uncomfortable with this entire communication. You did not respond, you seem to have baited me, etc. Please keep in mind that I have other communique from ROR, as well as this one, that are not in RORs best interest. Your lack of response may seem like you are doing some type of mind game with me, or playing with me, but you are really pissing me off. I am ready to withdraw any consideration that I may have given from before because you have caused my more upset and anxiety with this tactic. I just think that I need to get an attorney. I have not considered this up to this point but you are now messing with me emotionally, spiritually and making me sicker than I need to be, you have upset me to the point that I have lost 5 lbs, and I cannot eat, or sleep. I did not ask for you to send this or give me any false hope, you did this to me. Oh, so you know, I do believe that Millie Plemmons husband is dying. Try that on the humane side of ROR that has tortured me for over 5 days. You have no idea what this has done to me. I am paranoid, trembling, and want to cry. I hate ROR. In a message dated 1/15/2010 2:02:13 P.M. Eastern Standard Time, david@ripoffreport.com writes: Jan, So I finally figured how to send a PM on SEOmoz and since someone said that I should stop asking people to email me, I tried that option and then wouldn't you know it, you don't allow PMs!!! Arrrgh!! Anyway, I wanted to prove to you that I really am ROR's lawyer, so I pulled your email address from a report that you filed. Who else would have that access? 1 of 3 Dock7/t8/.2010ia.com e s Just 8:59 AM Gmail - Fwd: Hi Smitty....from David https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&search=st... Now, I was serious about saying that I probably won't post any further comments on SEOmoz. It's clear that you guys don't want to hear our side of the story. That's fine. I do respect your right to disagree with us. However, I want you to know that as inhumane as you think Ripoff Report is, we do have a heart. In fact, just last month I received a request from a lawyer in your neck of the woods asking us to remove a report....not because it was false, but because the guy named in the report had died, and he had a 16 year-old daughter who shared his unusual last name. When people were searching for her on Google, they found the report about her dead father which had lots of embarrassing details about him being a criminal, etc., and it was devastating to her. That lawyer did not threaten us and did not sue us. He just asked us to help a 16 year-old girl during the Christmas season. And guess what? We said YES....and in case you're wondering, we did not ask for and did not receive a dime for doing this. We did it simply because it was the right thing to do. Of course, we can't really advertise this because once we start saying that we're willing to help some people, it sort of opens the floodgates for everyone to demand the same treatment. I know you'd like it if we would just take down anything/everything when asked, but that's just not something Ed is willing to do at this point. Maybe someday, but not right now. Even though you have been blasting ROR for a long time, I am still willing to TRY to help you. I can't promise that Ed Magedson will agree, and I don't have the power to take down reports without his permission, but I will at least do my best to ask him to make an exception. In most cases, Ed is very reluctant to remove an entire report, but he may be willing to remove a single unique word or name so that people looking on Google won't find the report. In your case, I am trying to figure out what that word would be. I know your name is "Jan Martin Smith", and if you do a search for that entire name, the Ripoff Report does come up on page 1 of Google. However, if I search for just "Jan Smith", there are like 70 million hits and ROR is nowhere to be found. I'm not sure how many people would search for you using all three names. However, assuming Ed won't agree to take down every report, would it help if we removed the name "Martin"? If there's a different word that you think would be better to remove, let me know what that is. Again, I can't promise that Ed will agree to this, but I'm willing to at least ask him about it, and not because your right and we're wrong, and not because I am trying to shut you up. I just want to offer this as a small humanitarian gesture because that's MY policy. P.S. Due to the threats that have already been made against me, I'll redact my last name from this email even though it's easy enough to find. However, I am including my direct dial phone number. If you want to call that number, I will answer it unless I'm away from my desk. 2 of 3 7/8/2010 8:59 AM Gmail - Fwd: Hi Smitty....from David https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&search=st... ~David [last name redacted to protect the innocent] General Counsel Xcentric Ventures, LLC http://w ww .ripoffreport.com/ David@RipoffReport.com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-3196 3 of 3 7/8/2010 8:59 AM

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