Kabbaj v. Google Inc. et al
COMPLAINT filed Pro Se with Jury Demand against Amazon Inc., Google Inc., John Does 1-10, Yahoo Inc. - filed by Younes Kabbaj. (Attachments: #1 Exhibit 1-4, #2 Exhibit 5-10, #3 Exhibit 11-20, #4 Exhibit 21-23, #5 Exhibit 24-25, #6 Exhibit 26-27, #7 Exhibit 28-29, #8 Exhibit 30-31, #9 Exhibit 32, #10 Exhibit 33-35, #11 Exhibit 36-37, #12 Exhibit 38-41, #13 Civil Cover Sheet)(mdb)
DECLARATION OF KUN YOON
1. My name is Kun Yoon and I am over 21 years of age and have personal knowledge of the
facts contained in this Declaration. I am a Delaware resident and have been since February of 2009.
2. From September of 2012 until now, I periodically used a laptop to view 4 blog sites authored
by Mark Simpson starting with www.draculadancing.com, as well as to view Mr. Simpson’s Google+ and
Amazon.com Author pages, and the Amazon book pages for the Simpson novel “Mythical Sex in
Marrakesh” and other variations of this work. I viewed these internet postings while in Delaware, many
of which contained statements accusing Younes Kabbaj of criminal activity. I was also able to access
these posts via searches conducted through Google and Yahoo search engines.
3. These internet posts contained numerous allegations that Younes Kabbaj illegally stalked and
harassed Mark Simpson for several years, that he unlawfully accessed Mark Simpson’s private email and
bank accounts, that he sent out sexually explicit emails to children using Simpson’s email accounts, that
he emailed Simpson threatening pictures of machine guns. These posts also claimed that Younes Kabbaj
committed similar illegal acts against other coworkers at the American School of Marrakesh, including
conducting illegal surveillance upon his co-workers at their private homes and illegally accessing their
personal emails and telephone lines to intercept their private communications. Mark Simpson also
accused Younes Kabbaj of being involved with terrorism.
4. I made copies of these posts to refresh my recollection as to the exact language used to
describe Younes Kabbaj in these internet publications.
5. I am not a party to any litigation occurring between Younes Kabbaj and Mark Simpson, nor do
I derive any benefit from the outcome of such litigation. I am just a witness and individual that resides
and transacts business in Delaware, and who has viewed Simpson’s internet posts in Delaware.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: January 23rd, 2013
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