George S May Intl, et al v. Xcentric Ventures, et al

Filing 225

Separate Statement of Facts by Defendant Xcentric Vventures, LLC in support of Motion for summary judgment (Attachments: # 1 Certificate of Service # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit # 8 Exhibit # 9 Exhibit # 10 Exhibit # 11 Exhibit # 12 Exhibit # 13 Exhibit)(Borcia, James) (Incorrect Event Used - Docket Text Edited by Clerk's Office) Modified on 12/26/2006 (gma, ).

George S May Intl, et al v. Xcentric Ventures, et al

Doc. 225 Att. 8

Case 1:04-cv-06018

Document 225-9

Filed 12/22/2006

Page 1 of 2

EXHIBIT 13

Dockets.Justia.com

De

" 06 i i : 32a

Rip-off Report Case 1:04-cv-06018 Document 225-9

Filed 12/22/2006

4257999729

Page 2 of 2

p.2

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DECLARA nON OF C.S. BOWEN
C.S, BOWEN state as follows:
1. My name is C.S, Bowen, I am a resident of

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the State of Arizona, am over

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the age of 18 years, and if called to testify in court in this matter I could and would
truthfully testify to the following facts based upon my own personal knowledge,
2. I am currently employed by XCENTRIC VENTURES, L.L.C. ("Xcentric")

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as a content monitor. I have worked for Xcentric in this position since the spring of2003.
3, In my job as a content monitor, I am responsible for reviewing new po

stings

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that are submitted to the website

("Rip-Off Report").

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4. My job is to remove the following information from new postings: personal

financial information, credit card numbers, bank account numbers, social security
numbers, obscenities, and theats of violence. When we redact such information, we
sometimes place a note indicating the redaction.
5. Except as described in the previous paragraph, I am not permitted to, nor do

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I, change or add any content to (1) any posting; (2) any title or heading of any posting;
and/or (3) any other part of the Rip-off

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Report website.

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6, I am aware that George S. May International Company has fied a lawsuit

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against Xcentrc and others in which it has been alleged that Xcentric created or authored
those certain report which are attached to the affidavit of

ED MAGEDSON as Exhibit A

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bearing Bates Nos. GSMIC 0001--097.
7, I have personally reviewed these reports and I know that I did not create

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them or any par of them, nor do I have any information that such reports may have been
created by another employee or agent of Xcentric.

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I declare under penalty of peijury that the foregoing is true and correct.
EXECUTED ON: 12).0/06

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i 0297-1/MCS/MCS/562429_ vi