1 2 3 4 5 6 7 8 9 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 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 Attorneys for Defendants SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF SAN DIEGO – CENTRAL DIVISION 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JANE DOE NOS. 1-14, inclusive, individuals; Plaintiffs, v. 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 1 - 500, inclusive, 28 CONSOLIDATED WITH: Case No. 37-2017-00043712-CU-FR-CTL Case No. 37-2017-00033321-CU-FR-CTL DECLARATION OF MATTHEW WOLFE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION Date: Time: Judge: Dept.: February 1, 2019 9:00 a.m. Hon. Joel R. Wohlfeil C-73 Complaint Filed: June 2, 2016 Trial Date: March 8, 2019 [IMAGED FILE] Defendants. 26 27 LEAD CASE: Case No. 37-2016-00019027-CU-FR-CTL /// -1DECLARATION OF MATTHEW WOLFE IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION 1 2 I, Matthew Wolfe, declare: 1. I am over eighteen years of age. I am a defendant in this case. I have personal knowledge 3 of the facts stated in this declaration and, if called as a witness, could testify competently about 4 them. 5 2. I testified as the Person Most Knowledgeable for BLL Media, Inc. at its deposition in this 6 case. However, I am not and have never been an employee of BLL Media, Inc., nor have I ever 7 had any ownership interest in BLL Media, Inc. 8 3. BLL Media, Inc. owns, operates, and controls www.girlsdoporn.com, the website on 9 which Plaintiffs allege their videos were published. I have never operated, owned, or controlled 10 11 12 13 14 15 16 17 18 www.girlsdoporn.com. I have never posted content on www.girlsdoporn.com. 4. M1M Media, Inc. owns, operates, and controls www.girlsdotoys.com, a website on which Does Nos. 1, 2, 5, 9, 12, 14, and 22 allege their videos were published. 5. I have never personally distributed the videos referenced in Plaintiffs’ operative complaints. 6. I have never used any of the videos referenced in Plaintiffs’ operative complaints for my personal commercial benefit. 7. I have never personally received any monies or commercial benefit from any of the videos referenced in Plaintiffs’ operative complaints. 19 8. I have never entered into a contract with any of the Plaintiffs. 20 9. I maintain my own separate bank account. I do not share bank accounts with any of the 21 named defendants. My personal income is deposited into my bank account. No other defendant 22 deposits monies into my bank account to shield its income. Each entity defendant in which I 23 have ownership interest has its own separate bank account. 24 10. I have never held myself out as being liable for the debts of any of the other defendants. 25 11. The only named defendant entities in which I have ownership interest are Merro Media, 26 Inc., Merro Media Holdings, LLC, and M1M Media, Inc. I am not an officer, director, member, 27 manager, or employee of any named entity defendants other than Merro Media, Inc., Merro 28 Media Holdings, LLC, and M1M Media, Inc. -2DECLARATION OF MATTHEW WOLFE IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION 1 2 3 12. Me o Media, Inc., Merro Media Holdings, LLC, and MlM Media, Inc. maintain their own corpor te formalities. 13. Me o Media, Inc., Merro Media Holdings, LLC, and MlM Media, Inc. are each 4 adequately apitalized. Merro Media, Inc., Merro Media Holdings, LLC, and MlM Media, Inc. 5 have suffici nt capital to pay all reasonably anticipated liabilities. 6 7 14. Me o Media, Inc., Merro Media Holdings, LLC, and MlM Media, Inc. are not mere shell entitie for the affairs of any of the other named defendants. 8 I declar under penalty of perjury under the laws of the State of California that the information 9 contained · this declaration is true and correct to the best of my knowledge. 10 this J6ili day of November, 2018 at San Diego, C a l i ~ 11 c=;; - ~ 12 Matthew Wolfe 13 .... 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECL -3TION OF MATTHEW WOLFE IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION