Seiko Epson Corporation et al v. InkSystem LLC et al

Filing 304

DEFAULT JUDGMENT in favor of Epson America, Inc., Seiko Epson Corporation against AF LLC, ART LLC, Alado LLC, InkSystem LLC, Inkredible LLC LLC, KBF LLC, Karine LLC, Lucky Print LLC, Veles LLC, Andriy Kravchuk, Artem Koshkalda, Igor Bielov, Karine Vardanian, Kristina Antonova, Roman Taryanik, Vitalii Maliuk, Vladimir Slobodianiuk. (Granted per ECF No. 302 Order. Signed by Clerk of Court Debra K. Kempi on 1/16/2018. (Copies have been distributed pursuant to the NEF - LH)

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Annie S. Wang
Nevada Bar No. 10792/CA SBN 243027
J. Andrew Coombs, Of Counsel
CA SBN 123881 (Admitted Pro Hac Vice)
Wang Law Corporation
520 East Wilson Ave., Suite 200
Glendale, California 91206
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
James D. Boyle
Nevada Bar No. 08384
Holley Driggs Walch Fine Wray Puzey & Thompson
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Attorneys for Plaintiffs Seiko Epson Corporation
and Epson America, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Seiko Epson Corporation and Epson
America, Inc.,
Plaintiffs,
v.
InkSystem LLC, et al.,
Defendants.

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Case No. 3:16-cv-00524-RCJ-VPC
[PROPOSED] JUDGMENT
PURSUANT TO ENTRY OF
DEFAULT

This cause having come before this Court on the motion of Plaintiffs Seiko Epson
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Corporation and Epson America, Inc. (collectively “Plaintiffs”) for entry of default
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judgment and permanent injunction (“Motion”) against Defendants Inksystem LLC,
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Lucky Print, LLC, AF LLC, ART LLC, Inkredible LLC LLC, Andriy Kravchuk, Igor
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Bielov, Artem Koshkalda, Vitalii Maliuk, Veles LLC, Alado LLC, Karine LLC, KBF,
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LLC, Karine Vardanian a/k/a Karine Christ a/k/a Karine Crist a/k/a Karine Westbrook,
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Vladimir Slobodianiuk a/k/a Volodymyr Slobodianiuk a/k/a Vladimir Westbrook,
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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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Kristina Antonova a/k/a Krystyna Antonova a/k/a Kristy Antonova a/k/a Krystyna

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Antanova a/k/a Krystyna Taryanik, and Roman Taryanik (collectively, “Defendants”),

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and Sancase LLC, Vilacet LLC, Renoca LLC, Best Deal Cartridge, LLC, Privat Group

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LLC, Yava LLC and Danalop LLC (collectively, “Koshkalda’s Companies”);
AND, the Court having read and considered the pleadings, declarations and

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exhibits on file in this matter and having reviewed such evidence as was presented in

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support of Plaintiffs’ Motion;
AND, GOOD CAUSE APPEARING THEREFOR, the Court finds the following

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facts:
Plaintiffs are the owners of all rights in and to trademark registrations, including,

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but not limited to, the trademarks which are the subject of the registrations listed in

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Exhibit A (collectively the “Plaintiffs’ Trademarks”), attached hereto.

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Plaintiffs have complied in all respects with the laws governing trademarks and
secured the exclusive rights and privileges in and to the Plaintiffs’ Trademarks.
The appearance and other qualities of the Plaintiffs’ Trademarks are distinctive
and original.
Defendants are using Plaintiffs’ Trademarks or marks confusingly similar to

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Plaintiffs’ Trademarks, in connection with the importation, manufacture, distribution,

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sale and offer for sale of counterfeit and/or infringing ink cartridges bearing

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unauthorized reproductions or substantially similar copies of registered trademarks

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owned by Plaintiffs (“Unauthorized Product”).

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Defendants’ advertising, displaying, promoting, marketing, distributing, offering

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for sale and selling of the Unauthorized Product was engaged in willfully and

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intentionally, without leave or license from Plaintiffs, in violation of Plaintiffs’ rights in

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and to Plaintiffs’ Trademarks.

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The liability of the Defendants in the above-referenced action for their acts in

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violation of Plaintiffs’ rights is knowing and willful, and as such the Court expressly

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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finds that there is no just reason for delay in entering the default judgment and

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permanent injunction sought herein.

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The Court has previously found that Plaintiffs have shown that proceeds from

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Defendants’ infringement were deposited into a large number of bank accounts and also

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used to purchase valuable real estate, among other things. Dkt. 159.

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The Court has also found that Plaintiffs have shown that Defendants have and are

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likely to further liquidate and dissipate assets, that they have a history of transferring

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money to family members and using shell companies to hide assets or the source of

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money. Dkt. 159.

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The Court, as a result of Defendants’ dissipation, secreting, and hiding of assets

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and other bad faith acts, granted an Order for Asset Seizure and Impoundment against

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Defendants AF LLC, ART LLC, Inkredible LLC LLC, Andriy Kravchuk, Igor Bielov,

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Artem Koshkalda and Vitalii Maliuk on August 22, 2017 (“Asset Freeze Order”),

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enjoining them and any person, corporation or other entity acting in concert with them,

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from further transfer or other concealment of assets. Dkt. 159. After Defendant

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Koshkalda, with the assistance of co-Defendant Vladimir Westbrook, continued to act in

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violation of the Court’s Asset Freeze Order, individually, and through various shell

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companies, including but not limited to Sancase LLC, Vilacet LLC and Renoca LLC, the

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Court set a hearing requiring the personal appearance of both Koshkalda and Westbrook

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regarding their alleged contempt, but they failed to appear in violation of the Court’s

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Order and were found in contempt of Court. Dkt. 250 (“Contempt Order”). As a result

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of Koshkalda’s continued and undisputed violation of Court Orders, including of the

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Asset Freeze Order, an Amended Asset Freeze Order was issued as against Koshkalda

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and his companies as a direct result of his latest contempt.

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Therefore, based upon the foregoing facts, and GOOD CAUSE APPEARING

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THEREFOR, THE COURT ORDERS that this Judgment shall be and is hereby entered

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in the within action as follows:

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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1)

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matter hereof pursuant to 15 U.S.C. §§ 1051, et seq., 28 U.S.C. §§ 1331 and 1338.

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Service of process was properly made on the Defendants.

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2)

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Plaintiffs’ Trademarks, in connection with the importation, manufacture, distribution,

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sale and offer for sale of Unauthorized Product which infringes upon the Plaintiffs’

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Trademarks.

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3)

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concert and participation with them who receive actual notice of the injunction are

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This Court has jurisdiction over the parties to this action and over the subject

Defendants are using Plaintiffs’ Trademarks or marks confusingly similar to

The Defendants and their agents, servants, employees and all persons in active

hereby restrained and enjoined from:
Infringing the Plaintiffs’ Trademarks, either directly or contributorily, in

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a)

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any manner, including generally, but not limited to, manufacturing, reproducing,

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importing, advertising, selling and/or offering for sale any unauthorized product

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which features any of the Plaintiffs’ Trademarks, and, specifically:

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i)

Importing, manufacturing, distributing, advertising, selling and/or

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offering for sale the Unauthorized Product or any other unauthorized

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products which picture, reproduce, copy or use the likenesses of or bear a

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substantial similarity to any of Plaintiffs’ Trademarks;

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ii)

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selling and/or offering for sale in connection thereto any unauthorized

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promotional materials, labels, packaging or containers which picture,

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reproduce, copy or use the likenesses of or bear a confusing similarity to

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the Plaintiffs’ Trademarks;

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iii)

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likely to confuse, mislead or deceive purchasers, Defendants’ customers

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and/or members of the public to believe, the actions of Defendants, the

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counterfeit products and related merchandise manufactured, sold and/or

Importing, manufacturing, reproducing, distributing, advertising,

Engaging in any conduct that tends falsely to represent that, or is

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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offered for sale by Defendants, or Defendants themselves are connected

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with Plaintiffs, are sponsored, approved or licensed by Plaintiffs, or are

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affiliated with Plaintiffs;

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iv)

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importation, manufacture, distribution, advertising, sale and/or offer for

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sale or other use of any goods or services, a false description or

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representation, including words or other symbols, tending to falsely

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describe or represent such goods as being those of Plaintiffs.

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4)

Affixing, applying, annexing or using in connection with the

Defendants, jointly and severally, shall pay damages to Plaintiffs in the sum of

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Twelve Million Dollars ($12,000,000.00).

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5)

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these proceedings, as follows: Dkts. 88 (Kravchuk: $16,146.50), 137 (Bielov/AF LLC,

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jointly and severally: $6,173.65, Maliuk/Inkredible LLC LLC, jointly and severally:

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$8,898.45), and any sanctions entered pursuant to Dkt. 175. The obligations under this

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Paragraph 5 are separate and distinct from the obligations under Paragraph 4 above, and

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satisfaction of one shall not constitute satisfaction of the other.

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6)

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pursuant to 28 U.S.C. § 1961(a).

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7)

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Order and Order for Seizure and Impoundment entered on September 13, 2017 [Dkt. 9],

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and the Preliminary Injunction entered on October 21, 2017 [Dkt. 33], are transferred

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and released to Plaintiffs immediately for destruction or other disposition. Defendants

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are entitled to no credit against the amounts due under this Judgment for such items.

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8)

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Temporary Restraining Order; Order For Asset Seizure And Impoundment; Order To

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Show Cause Re Issuance Of Pre-Judgment Asset Freeze entered on July 31, 2017

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[Dkt. 105-106], the Order for Asset Seizure and Impoundment entered on August 22,

The following Defendants shall also pay all sanctions issued against them in

All amounts described in Paragraphs 4 and 5 of this Judgment shall bear interest

The items seized and currently stored pursuant to the Temporary Restraining

Title and ownership in the $314,657.47 and any other cash assets frozen by the

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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2017 [Dkt. 109], the Order re Contempt as to Artem Koshkalda and Vladimir Westbrook

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entered on October 27, 2017 [Dkt. 250], and the Amended Order for Asset Seizure and

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Impoundment entered on October 27, 2017 [Dkt. 251], including but not limited to those

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assets identified in the attached Exhibit B to this Judgment, are Ordered to be

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immediately assigned or otherwise transferred to Plaintiffs or accounts identified by

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Plaintiffs, the value of such assets to be deducted against amounts owed pursuant to this

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Order.

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9)

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Companies’ real estate assets, including but not limited to those identified in the attached

Plaintiffs may enforce this Judgment against Defendants’ and/or Koshkalda’s

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Exhibit C.

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10)

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person acting in concert with them, whether acting directly or through any entity,

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corporation, subsidiary, division, affiliate or other device, or any third-party service

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provider who is served with a copy of this Order or has knowledge of this Order by

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personal service or otherwise, are enjoined and restrained from:

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Effective immediately and until the Judgment is satisfied in full, Defendants, any

a) Transferring, converting, encumbering, selling, concealing, dissipating,

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disbursing, assigning, spending, withdrawing, perfecting a security interest in, or

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otherwise disposing of any funds, real or personal property, accounts, contracts,

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or other assets, wherever located, including outside the United States, including

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but in no way limited to those accounts and assets identified in Exhibits B and C,

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that include, consist of in any amount, were derived from, or were purchased with

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any profits, proceeds or monies received from the sale of any unauthorized Epson

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branded ink cartridge, and are:

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i) owned or controlled by, or in the actual or constructive possession of any

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Defendant; or
ii) owned or controlled by, or held for the benefit of, directly or indirectly, any
Defendant, in whole or in part; or

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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iii) owned or controlled by, or in the actual or constructive possession of or

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otherwise held for the benefit of, any corporation, partnership, or other entity

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directly or indirectly owned, managed, or controlled by any of the Defendants

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(including but not limited to Koshkalda’s Companies), including, but not

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limited to, any assets held by, for, or subject to access by, any of the

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Defendants at any bank or savings and loan institution, or with any broker-

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dealer, escrow agent, title company, or other financial institution or

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depository of any kind.

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b) Opening or causing to be opened any new accounts or safe deposit boxes titled in

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the name of any Defendant, or subject to access by any Defendant, that will

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receive any profits, proceeds or monies received from the sale of any

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unauthorized Epson branded ink cartridge;

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c) Obtaining a personal or secured loan encumbering the asset of any Defendant, or

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subject to access by any Defendant, where the asset consists of in any amount,

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was derived from, or was purchased with any profits, proceeds or monies

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received from the sale of any unauthorized Epson branded ink cartridge;

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d) Incurring liens or other encumbrances on real property, personal property, or

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other assets in the name, singly or jointly, of any Defendant or of any

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corporation, partnership, or other entity directly or indirectly owned, managed, or

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controlled by any Defendant, where the asset consists of in any amount, was

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derived from, or was purchased with any profits, proceeds or monies received

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from the sale of any unauthorized Epson branded ink cartridge; or

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e) Incurring charges or cash advances on any credit card or prepaid debit, credit or

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other bank card, issued in the name, singly or jointly, of any Defendant or any

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corporation, partnership, or other entity directly or indirectly owned, managed, or

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controlled by any Defendant, where the asset consists of in any amount, was

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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derived from, or was purchased with any profits, proceeds or monies received

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from the sale of any unauthorized Epson branded ink cartridge.

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11)

The bond filed on September 15, 2017, as Dkt. 11 is hereby exonerated.

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12)

This Judgment shall be deemed to have been served upon Defendants at the time

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of its execution by the Court and entry by the Clerk of the Court.

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13)

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pursuant to Rule 54(a) of the Federal Rules of Civil Procedure, the Court directs

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immediate entry of this Judgment against Defendants.

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14)

The Court finds there is no just reason for delay in entering this Judgment and,

The Asset Freeze Order [Dkt. 159], the Contempt Order [Dkt. 250], and the

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Amended Asset Freeze Order [Dkt. 251], shall remain in full force and effect through

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any period of stay or applicable non-enforcement period of this Judgment.

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[Dkt. 250], and the Amended Asset Freeze Order [Dkt. 251], shall be incorporated into

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this Judgment and will survive the entry of this Judgment:

The following terms of the Asset Freeze Order [Dkt. 159], the Contempt Order

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a) Plaintiffs are given leave to immediately attach and execute upon any assets

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owned or controlled by, or in the actual or constructive possession of or

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otherwise held for the benefit of, any corporation, partnership, or other entity

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directly or indirectly owned, managed, or controlled by Defendant Koshkalda or

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one of his companies (including but not limited to Sancase LLC, Vilacet LLC,

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and Renoca LLC) including but not limited to those assets identified in Exhibit A

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and B. Plaintiffs have leave to submit proposed writs or other orders as may be

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necessary to attach and/or execute upon any assets pursuant to this Judgment;

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b) Koshkalda and those acting in concert with him who are subject to the

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jurisdiction of this Court, including but not limited to Andriy Kravchuk and

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Vladimir Westbrook, are ordered to appear for examination under oath before

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Magistrate Judge Cooke, or another special master as the Court sees fit, at a date

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and time to be set by Magistrate Judge Cooke or special master within 28 days of

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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the entry of this Order, to account for all of Koshkalda’s assets and recent

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transactions, including the identification and whereabouts of all of the proceeds

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from real estate transactions during the pendency of this action;
c) Koshkalda and those acting in concert with him who are subject to the

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jurisdiction of this Court, including but not limited to Andriy Kravchuk and

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Vladimir Westbrook, are further ordered to produce, within ten days following

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this order, all documents for all of Koshkalda’s assets and recent transactions,

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including all documents the identification and whereabouts of all of the proceeds

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from real estate transactions during the pendency of this action;

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d) Plaintiffs are given leave to undertake discovery, including Debtor’s

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examinations and third-party discovery, regarding the assets and obligations of

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Defendants and those acting in concert with them;
e) Koshkalda, ART LLC, and Westbrook shall deposit into a frozen account all

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proceeds from any real estate transaction completed since August 1, 2017; and

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f) Defendants’ bank accounts are impounded, as provided in Paragraph 14 of the
Amended Seizure Order.

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16)

The Court shall retain jurisdiction of this action, specifically including any

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Contempt and Sanctions Orders entered, to entertain such further proceedings and to

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enter such further orders as may be necessary or appropriate to implement and enforce

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the provisions of this Judgment and any orders of this Court.

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IT IS SO ORDERED.

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January 16, 2018
_______________________________
UNITED STATES DISTRICT JUDGE

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Dated: ___________________________

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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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EXHIBIT A
1

SEC’S TRADEMARKS

2

Registration
Date of
Number
Registration

Class(es)
of Goods

3

Trademark

4

EPSON

1,134,004

4/29/1980

9

EPSON

2,144,386

3/17/1998

2, 9 and
16

EPSON

2,949,374

5/10/2005

16

EPSON

3,092,025

5/16/2006

9

EPSON

3,520,274

10/21/2008

9

3,448,351

6/17/2008

2, 9 and
16

3,875,333

11/16/2010

2, 9, 16
and 40

2,644,235

10/29/2002

2

5
6
7
8
9
10
11
12
13
14
15
16
17

DURABRITE

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19
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SEC, et al. v. Inksystem, LLC, et al.: [Proposed] Order

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1

EXHIBIT B

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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

Financial Institution
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Bank of America, N.A.
Citibank Fsb
Citibank Fsb
Citibank Fsb
U.S. Bank, N.A.
U.S. Bank, N.A.
U.S. Bank, N.A.
U.S. Bank, N.A.
U.S. Bank, N.A.
U.S. Bank, N.A.
Wells Fargo Bank, N.A.
Wells Fargo Bank, N.A.
Wells Fargo Bank, N.A.

Account
1744
6624
7115
7255
3491
6702
6715
9178
9275
2263
0310
0394
8964
8977
8980
8533
8591
8760
9099
0519
0087
0090
0100
0155
8374
8390
8382
5442
5459
5467
2778
2869
2992
0399
4158
7982

Account Name/Holder
ARTEM KOSHKALDA
ART LLC
ART LLC
ARTEM KOSHKALDA
ART LLC
Inkredible LLC
Inkredible LLC
AF LLC
AF LLC
Inkredible LLC
Inkredible LLC
Inkredible LLC
ART LLC
ART LLC
ART LLC
ART LLC
ART LLC
Renoca LLC
Privat Group LLC
Artem Koshkalda
Artem Koshkalda
Artem Koshkalda
Artem Koshkalda
Artem Koshkalda
Art LLC
Art LLC
Art LLC
Inkredible LLC LLC
Inkredible LLC LLC
Inkredible LLC LLC
Igor Bielov dba AF LLC
Igor Bielov dba AF LLC
Igor Bielov dba AF LLC
Artem Koshkalda
Artem Koshkalda dba ART
Artem Koshkalda dba ART

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$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$

Balance
1.00
90.10
38,324.05
118.13
449.00
286.46
64.83
1.05
5.09
1,322.16
1,519.10
580.96
96.00
96.00
6,006.00
118.00
96.69
80.79
254,406.77
4,249.11
121.65
113.00
395.82
113.00
23.44
47.57
19.57
1,557.72
138.75
1,705.27
5.50
14.42
31.46
50.00
71.63
2,211.38

1
2
3

Wells Fargo Bank, N.A.
Wells Fargo Bank, N.A.
Wells Fargo Bank, N.A.
Wells Fargo Bank, N.A.

7966
8446
2935
7974

Artem Koshkalda dba ART
Artem Koshkalda
Artem Koshkalda dba ART
Artem Koshkalda dba ART

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
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$
$
$
$

78.00
20.00
20.00
8.00

EXHIBIT C
1

Owner

2
3

1

Address

APN

Recent History

Artem
Koshkalda

38868 Thimbleberry Place
Newark, CA 94560

92A260018

Reportedly Listed for
Sale on 8/13/17

4
5

2

Artem
Koshkalda

401 Harrison St., #4D
San Francisco, CA 94105

3765417

3

Artem
Koshkalda

388 Fulton St., #207
San Francisco, CA 94102

0785072

6
7
8
9
4

Artem
Koshkalda

11 Franklin St., # 502
San Francisco, CA 94102

0837117

5

Artem
Koshkalda

338 Portrero Ave., #402
San Francisco, CA 94103

3962032

6

Artem
Koshkalda

253 Friedell St.
San Francisco, CA 94124

4591C-462

7

10

Artem
Koshkalda

401 Harrison St., #4A
San Francisco, CA 94105

3765414

8

Artem
Koshkalda

11 Franklin St.,
San Francisco, CA 94102
(identified by Defendant as
Unit #205)

0837003

11
12
13
14
15
16
17
18
19
20
9
21
22
23

10

24
11
25
26

12

Artem
Koshkalda
& Andriy
Kravchuk
Artem
Koshkalda

Artem
Koshkalda

Transferred to Vilacet
LLC/
Reportedly Listed for
Sale on 8/13/17
Transferred to Vilacet
LLC/
Reportedly Listed for
Sale on 8/14/17

Transferred to
Sancase LLC/
Reportedly Listed
for Sale on 8/13/17
Transferred to
Sancase LLC/
Reportedly Listed
for Sale on 8/14/17
Transferred to Renoca
LLC/
Reportedly not for sale
Transferred to Vilacet
LLC/
Reportedly not for sale

Reportedly not for sale

One Mission Bay Property
(address unknown)

Tanglewood by
Summerhill Homes
Property (address
unknown)
Saverio/Pulte Homes
Property (address
unknown)

Any other real estate properties acquired by Defendants after August 1, 2017.

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PROOF OF SERVICE
I, the undersigned, certify and declare that I am over the age of 18 years, employed in the
County of Los Angeles, and not a party to the above-entitled cause. I am employed by a member
of the Bar of the United States District Court of Nevada. My business address is 520 East Wilson
Avenue, Suite 200, Glendale, California 91206.
On November 14, 2017, I served on the interested parties in this action with:
PLAINTIFFS’ NOTICE AND MOTION FOR ENTRY OF DEFAULT JUDGMENT
DECLARATIONS AND EXHIBITS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
ENTRY OF DEFAULT JUDGMENT
[PROPOSED] JUDGMENT PURSUANT TO ENTRY OF DEFAULT
in support for the following civil action:
Seiko Epson Corporation, et al. v. InkSystem LLC, et al.
_x_ via the United States District Court CM/ECF system;
_x_ by email to [e-mail] for Defendants Artem Koshkalda and ART LLC
per Defendant Koshkalda’s request;
Artem Koshkalda
1280 Terminal Way, Ste. 28
Reno, NV 89502
[via email to [e-mail] per
Defendant’s request and via ECF]

Art LLC
1280 Terminal Way, Ste. 28
Reno, NV 89502
[via email to [e-mail] per
Defendant’s request]

x
___ by placing a true copy thereof in an envelope to be immediately sealed thereafter to the
below Defendants. I am readily familiar with the office’s practice of collecting and processing
correspondence for mailing. Under that practice it would be deposited with the United States
Postal Service on the same day with postage thereon fully prepaid at Glendale, California in the
ordinary course of business. I am aware that on motion of the party served, service presumed
invalid if postal cancellation date or postage meter is more than one day after date of deposit for
mailing in affidavit.
InkSystem LLC
1000 Bible Way, Apt. 40
Reno, NV 89502
Vitalii Maliuk
675 Fairview Dr., Ste. 233
Carson City, NV 89701

Lucky Print LLC
1000 Bible Way, Apt. 40
Reno, NV 89502
Inkredible LLC LLC
675 Fairview Dr., Ste. 233
Carson City, NV 89701

Proof of Service
Page 2 of 2

Andriy Kravchuk
1000 Bible Way, Apt. 40
Reno, NV 89502
AF LLC
390 Freeport Blvd., Ste. 6
Sparks, NV 89431
Vladimir Slobodianiuk a/k/a Volodymyr
Slobodianiuk a/k/a Vladimir Westbrook
935 Sharmon Palms Lane, Apt. C
Campbell, CA 95008
Karine Vardanian a/k/a Karine Christ a/k/a
Karine Crist a/k/a Karine Westbrook
935 Sharmon Palms Lane, Apt. C
Campbell, CA 95008
Veles LLC
1280 Terminal Way #28
Reno, NV 89502

Karine LLC
1280 Terminal Way #28
Reno, NV 89502
KBF LLC
c/o Nevada Secretary of State
202 N. Carson St.
Carson City, NV 89701

Igor V. Bielov
390 Freeport Blvd., Ste. 6
Sparks, NV 89431
KBF LLC
935 Sharmon Palms Lane, Apt. C
Campbell, CA 95008
KBF LLC
c/o Volodymyr Slobodianiuk
2787 Moorpark Ave.
San Jose, CA 95128
Alado LLC
1280 Terminal Way #28
Reno, NV 89502
Kristina Antonova a/k/a Krystyna Antonova
a/k/a Kristy Antonova a/k/a Krystyna Antanova
a/k/a Krystyna Taryanik
3408 Chitgar Place
San Jose, CA 95117
Roman Taryanik
3408 Chitgar Place
San Jose, CA 95117

Place of Mailing: Glendale, California
Executed on November 14, 2017 at Glendale, California

___________________________
Katrina Bartolome