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This started as a visual representation of Paul Hansmeier's depo. It has been updated with facts and references as I find them. Dots indicate contradictory statements. Colors on the left indicate address sharing.
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undefined beneficiary
trust
wholly owns40 PH_dep
created by Aisha Sargeant 40 PH_dep
owned by Salt Marsh 45 PH_depowned by Salt Marsh P_ex100 PH_dep
LLC organized under the laws of the Federation of St. Kitts & Nevis
55 PH_dep
PH does not know who paid AS to create the trust 71 PH_dep
Lutz asked AS to form AF Holdings74 PH_dep
AS works for Trust Services Limited "TSL"
74 PH_dep
Lutz asked TSL to form AF Holdings
74 PH_dep
Lutz was not instructed by a third party to form AFH 75 PH_dep
Anti-Piracy Law Group88 PH_dep
Prenda Law
91 PH_dep
settlement proceedings
go into
Mr. Steele has no right to these trust accounts: 93 PH_dep
PH has no right to these trust accounts: 94 PH_dep
Alpha has not withdrawn from Prenda Trust account
98 PH_dep
Money has transferred out only for litigation expenses, nothing else
106 PH_dep
Alpha has not received compensation from113 PH_dep
several dozen112 PH_dep
most attorneys are paid on contingency 110 PH_dep
33%115 PH_dep
Alan Cooper corporate representative of AFH
121 PH_dep
Protect ML from being targted122 PH_dep
Paul Godfreadrepresents Cooper
122 PH_dep
Raymond Rogers assigns to assignee, signed by Cooper
125 PH_depone employee - Mark Lutz
127 PH_dep
PH never worked for Prenda 130 PH_dep
ML worked for Steele Hansmeier130 PH_dep
ML worked for Steele. PH never delegated anything to him132 PH_dep
Brett Gibbs in-house for AFH133 PH_dep
Alpha has no employees
134 PH_dep
created by Aisha Sargeant May 20, 2011 21 PH_dep
Michael Dugas worked for AFH but not as employee 135 PH_dep
Michael Dugas worked at Prenda 136 PH_dep
Michael DugasML manages 20 attys, 50 cases
141 PH_dep
ML given ths role by AS141 PH_dep
given the role by AS at the direction of ML 141 PH_dep
Anthony Saltmarsh also corp rep 143 PH_dep
PH met Steel in Law school 144 PH_dep
Lived with Steele's sister 144 PH_dep deputized by AS
147PH_dep
Heartbreaker Digital, LLC is assignor153 PH_dep
work title Popular Demand154 PH_dep
negotiated by Lutz and Rogers, not Steele 125 PH_dep
155 PH_dep
6681 Forensics
162 PH_dep
PH is not shareholder, officer, nor employee
162 PH_depPH has a 6681 email
162 PH_dep
Peter H is technician, and PH's brother 166 PH_dep
Media Copyright Group169 PH_dep
Started 6/21/10timeline MCGIP Inc.
169 PH_dep
PH not familiar170 PH_dep
PH was organizer and technician 171 PH_dep
PH was orqanizer170 PH_dep
performs tech services171 PH_dep
maybe for S|H172 PH_dep
uses software called "Alena"
174 PH_dep
after 2011 provided IP addresses to S|H
176 PH_dep
ISPs are world-class regaring IP identification
189 PH_dep
ML delegates to attys and contractors like 6681
194 PH_dep
never files taxes in Nevis or US196 PH_dep
no accountant 198 PH_depbooks are spreadsheets
198 PH_dep
no way to determine revenue200 PH_dep
not very complicated198 PH_dep
claims on the cash, it's very complicated202 PH_dep
snark
202 PH_dep
Alpha has been reimbursed by
205 PH_dep
Alpha has never paid 6681
206 PH_dep
Prenda pays 6681206 PH_dep
ML is only person at AFH with authority to settle a case
208 PH_depAttys across the country can settle 208 PH_dep
Prenda law helps Lutz decide who to sue 211 PH_dep
CA and IL. Paul Duffy is principal 211 PH_dep
Paul Duffy is principal211 PH_dep
Private investigators, yes215 PH_dep
signatures look a lot alike235 PH_dep Ex109
PH represented Alan Mooney in the Priceline litigation 244 PH_dep
PH and AM met while PH was at a firm 247 PH_dep
AM is manager of MCGIP, LLC
249 PH_dep
held copyrights and produce content
250 PH_dep
Steele is not affiliated with Alpha
255 PH_dep
Prenda filed substitution of counsel in S|H cases across the board
257 PH_dep
S|H filed notice of dissolution with Sec of State 256 PH_dep
PH had no formal affiliation with Prenda 257 PH_dep
Steele handled the money that was in the S|H trust account
257 PH_dep
Gibbs was of counsel to S|H258 PH_dep
Alpha represented Guava in a MN case 238 PH_dep
6681
AF
AFAF
87 PH_dep
Anderson & Associates
AF
AF
AF
95 PH_dep
If Alpha Law Firm wins $ goes into Prenda account81 PH_dep
proceeds of settlements generated aren't distributed to AF Holdings, but are instead used to either pay for previously incurred expenses or held by the attorneys to pay for future litigation expenses.
trust accounts
6681
6681
Dissolving
explosion
259 PH_dep
Cathy in writes reimbursement checks 99 PH_dep
BUT...
Documents reviewed for depo prep:
certificate of formation
articles of organizationdoc that listed Aisha Sargeant as organizer
59 PH_dep
Pietz identifies three people associated with a trust in Nevis:SettlerBeneficiaryTrustee 69 PH_dep
AF
6681
Steele, John
Mooney
Hansmeier, Paul
Hansmeier, Peter
Cooper, Alan
Lutz, Mark
Sargeant, Aisha
Steele Hansmeier, LLC
Trust
Alpha Law Firm
AF Holdings LLC
Gibbs, Brett
6681 Forensics
Prenda Law
Duffy, Paul
Anti-Piracy Law Group
role is to...
Guava, LLC
Media Copyright Group, LLC
downloads files and compares them to Work to ensure substantial similarity. Stores data in central database. (MCG)
PH Dec 09/02/1010
PH_DepPH Dec 09/02/1010
David Pfister
David Pfister technician
Pfister dec
Pfister dec
Pfister DecPeter Dec
Peter H does this stuff too Peter dec
©
©
Spencer Merkel
Merkel Aff
Guava sued Spencer Merkel. OR resident sued in MN Merkel aff
Trina Morrison
Merkel affSpencer rep'ed by Trina Morrison
Merkel affDuffy signed Prenda threat letter
Merkel complaint
Dugas attorney through Alpha for Guava Merkel Complaint
Spencer called Prenda and talked to "Michael" who was working for Alpha
Merkel Aff
?ed: not sure if this is the case
Dugas?
Ingenuity 13, LLC
ML asked Steele for a representative. Steele delivered Cooper
122 PH_dep
Cooper sues Steele et al for identity theft
Coopliant
Coopliant
Phil Handymeyer DepoPH Declaration 09/02/1010Pfister Declaration 02/02/2011Peter Declaration 01/31/2012Merkel Affadavit 01/25/2013Merkel Complaint Hacking 10/17/2012Cooper Complaint 1/23/2103
Documents ReferencedTrain Wreck Key
Nguyen Nguyen hearing 11/27/2011
Mark "No coat No tie" Lutz3 Nguyen
2 Nguyen
Johnathan Torres
J Torres, FL counsel for Sunlust
Torres was contacted by Gibbs to be local consel 5 Nguyen
Prenda told court they are not involved in this case 4 Nguyen
Torres' cut is 75% 6 Nguyen
Does not know Duffy 11 Nguyen
Steele is not involved with Prenda nor this case 12 Nguyen
Lutz is corporate rep of Sunlust, not an officer 14 Nguyen
Gets $1000 to appear in court 15 Nguyen
Torres does not know Lutz 15 Nguyen
Lutz not authorized to bind Sunlust14 Nguyen
Also rep for Hard Drive and Guava17 Nguyen
Sunny Leone
Sunny Leone is president of Sunlust17 Nguyen
Steele no longer actively practices law 11.27.0219 Nyugen
Trib 03/10 Star Tribune 03/10/2013
Mooney listed as sole organizer Trib 03/10
Mooney denies knowledge Trib 03/10
PH sent the Star Tibune affidavits declaring suchTrib 03/10
@JohnHenryLawyer
D Weber is principal12 Doe OSC
DW is out of the country, id
Lie, he is in LA,id
Salt Marsh Owns AF Holdings26(f) 2.14.12
Salt Marsh
daniel weber
Jayme Steele14 Doe OSC
Address in AZ is same VPR Inc14 Doe OSC
Address in AZ is same notissues.com14 Doe OSC
Doe OSC
AC is registrant, but Steele email. 14 Doe OSC
Alan "Mony" signed false verificationDoe OSC 15
also in-house for Guava and LivewireDoe OSC 18
Steele is of counsel to Prenda 2.13.1318 Doe OSC
ML founder LivewireDoe OSC 20
Livewire bought AFH the before the PH Dep28 Doe OSC
Doe OSC response 2.19.1326(f) 2.14.12 26(f) Report 2.14.13, AFH v Does 1-135
Created 05/201121 PH_dep
Sirh-Ryun Stella Wi Dugas address is Alpha mncourts.gov
Sirh-Ryun Stella Wi Dugas
married
Paul says she did not work for Alpha. 135 PH_dep
SRSWD worked for LiveWire Holdings LLC LinkedIn via SDJ
LiveWire is in a UPS store in DC LinkedIn via SDJ
LiveWire "Systems" in Hubbard case 13-L-15
13-L-15 LW Systems re Hubbard (hacking)
Adam Urbanczyk
Hubbard defense atty is Adam Urbanczyk SDJ 2013/01/31
SRSWD was an attorney with Prenda Sundarrajan
Pecadeso AF v Pedadeso 2.30.2013 orderSundarrajan AF v Sundarrajan declaration 10.30.2012
SRSWD an AF attorney Pecadeso
1111 Lincoln Road, Suite 400, Miami Beach, FL 33139
80 S 8th Str #900Mpls, MN 55402
161 N. Clark St. Suite 3200, Chicago IL 60601
Livewire Holdings, LLC2100 M St. NW Suite 170-417Washington DC 200037
LiveWire
Steel Law Firm
2135 CityGate Ln, Suite 300Naperville, IL 60563
Peter H is technician Peter Decl 6.6.2011
Peter Decl 6.6.2011 Peter Declaration 06/06/2011
Peter H is Manager http://mblsportal.sos.state.mn.us
Dissolved 12.22.2011Trib 1.30.2013
Trib 1.30.2013 Jason Sweet Declaration 1.30.2013
1/13/2012 Trib 1.30.2013
incorporatedMN 9.9.2010Trib 1.30.2013
IL 6292158
MN 0387795
CA 251000
IL 6210496
Appeared in PacificCentury on 2/24/2012Trib 1.30.2013
Gibbs Dec Gibbs' 3.1.2013 Declaration
Of Counsel to S|H. Hired 2.14.2011Gibbs Dec switch to Prenda
Nov 2011
Gibbs reported to Steel and PHGibbs Dec
Instructions & Guidelines
Report
Structure at S|H & Prenda
Steele, PH, and Lutz all work for LivewireGibbs Dec
Heartbreaker
Springates EastGovernment RoadCharlestown, NevisGibbs Dec
Springates EastGovernment RoadCharlestown, Nevis
Popular Demand
(c) Heartbreaker8.9.2011
PA0001754383
12.20.2011AF Holdings LLCassigned to
A Peek Behind the Scenes at a ShowPA0001802629
8.24.2012
Ingenuity 13, LLC
Five Fan FavoritesPA0001791654
5.29.2012
AF Holdings LLC
Spencer agreed to be sued and provide his BT logs in exchange for dismissal Merkel aff
Merkel affBased on Prenda advice
27-CV-12-20976
Plaintiffs and their titles
Matching colored dots indicate conflicting facts
ed: that's just funny!
ed: who else imagines Steele, his Sister, Saltmarsh, and a bunch of Alan Coopers living in an Apartment running notissues.com?
That's just funny
Hit the DOWNLOAD button
Trans0402 Transcript 4.2.2013 hearingTrans0311 Transcript 3.11.2013 hearingGibbs Dec 12.21.12 Gibbs' 12.21.2012 Declaration
Of Counsel for PrendaGibbs Dec 12.21.12
Gibbs11.18.2012 Gibbs' 11.18.2012 letter to judge Scriven
Sole principal of PrendaDuffyLetter11.18.12
Steele Law opens 2008 Steele Aff 12.20.2012
SteeleAff12.20.2012 Steele Affidavit in Sunlust v Nguyen
Duffy & Steele known each other since law school Steele Aff 12.20.2012
Steele Law filed w/ IL Sec of State 5.7.2007Steele Aff 12.20.2012
MerkelTran1.25.13 Transcript of Merkel Hearing 1.25.2012
Morrison and Dugas are friends and went to U of MN Law together MerkelTran1.25.13
PH refers to Alpha Law Group
255 PH_dep
PH says there is no Alpha Law Group
255 PH_dep
slip of the tongue?
No formal affiliation 256 PH_dep
Mar11 Transcript of March 11 hearing
and in-house for AF Mar11 105
"Carl" worked with Gibbs-maybe auth to use ECFMar11 106
PH had Gibbs'ECF credentials Mar11 105
Gibbs told someone that negotiations go through him Mar11 94
Gibbs was secratary for local counsel in other states Mar11 109
Steele had access to Gibbs' email Mar11 110
Atty for Alpha but used wefightpiracy email address Merkel Complaint
Lutz 420 Declaration of Mark Lutz - no date
membership interests in AFH are held in trust
Lutz420
Lutz's childern are benficiaries Lutz420
HoldingsAF
Accord Assets
MCGIP LLC
S|H
Guava is a Nevis corpMerkelTran1.25.13 p9
AF
Started 10/7/10timeline
URL reg'ed 9/13/11Timeline
AF
