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PANAKOS LAW, APC
Aaron D. Sadock (SBN 282131)
555 West Beech Street, Ste. 500
San Diego, California 92101
Telephone:
(619) 800-0529
Facsimile:
(866) 365-4856

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LAW OFFICES OF DANIEL A. KAPLAN
Daniel A. Kaplan (SBN 179517)
Alexandra R. Byler (SBN 294307)
555 West Beech Street, Suite 230
San Diego, California 92101
Telephone:
(619) 685-3988
Facsimile:
(619) 684-3239

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Attorneys for Defendants
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SUPERIOR COURT OF CALIFORNIA

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COUNTY OF SAN DIEGO - CENTRAL DIVISION

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JANE DOE NOS. 1-14, inclusive,
individuals;

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Plaintiffs,
V.

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DECLARATION OF MICHAEL PRATT

IN SUPPORT OF DEFENDANTS'
MOTION TO QUASH SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
TO CLOUDFLARE, INC.

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Case No. 37-2016-00019027-CU-FR-CTL

GIRLSDOPORN.COM, a business
organization, form unknown; MICHAEL J.
PRATT, an individual; ANDRE GARCIA,
an individual; MATTHEW WOLFE, an
individual; BLL MEDIA, INC., a California
corporation; BLL MEDIA HOLDINGS,
LLC, a Nevada limited liability company;
DOMI PUBLICATIONS, LLC, a Nevada
limited liability company; EG
PUBLICATIONS, INC., a California
corporation; MlM MEDIA, LLC, a
California limited liability company;
BUBBLEGUM FILMS, INC., a business
organization, form unknown; OH WELL
MEDIA LIMITED, a business organization,
form unknown; MERRO MEDIA, INC., a
California corporation; MERRO MEDIA
HOLDINGS, LLC, a Nevada limited liability
company; and ROES l - 500, inclusive,

Date:
Time:
Referee:
Location:

TBD by Discovery Referee
TBD by Discovery Referee
Hon. Thomas Nugent (Ret.)
Judicate West
402 W. Broadway Suite 2400,
San Diego, CA 92101

Assigned to: Hon. Gregory W . Pollack;
Dept. C-71

Complaint Filed: June 2, 2016
Trial Date: July 13, 2018
[IMAGED FILE]

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Defendants.
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DECLARATION OF MICHAEL l?RATT IN SUPPORT Of, DEFENDANTS'
MOTION TO QUASH SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS TO CLOtIDFLARE
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I, Michael Pratt, declare:
1. As a manager or officer of the following defendants in this matter, Girlsdoporn.com, BLL

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Media, Inc. , BLL Media Holdings, LLC, EG Publications, Inc., MlM Media, LLC, and

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Bubblegum Films, Inc. ( collectively "Defendants"), 1 have personal knowledge of their business

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operations.

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2. The Defendants and I have never owned, controlled, been the administrator of, posted

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videos to, or received revenues from www.SpankBang.com ("SpankBang" or "the website"), a

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pornography website. In the past, I have had my attorneys send "DMCA" notices to SpankBang

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to demand that videos be taken down from the website because the videos were stolen from

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Defendants' websites and posted without authorization.

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I declare under penalty of perjury under the laws of the State of California that the
information contained in this declaration is true and correct to the best of my knowledge.

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. ---lh

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Executed this ~ day of October, 2017 at San Diego, California.

~~~

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DECLARATION OF MICHAEL PRATT IN SUPPORT OF DEFENDANTS'
MOTION TO QUASH SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS TO CLOUDFLARE
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