Jane Doe 3

1 Robert Hamparyan (State Bar No. 181934) HAMPARYAN INJURY LAWYERS, APC 2 275 W. Market Street San Diego, CA 92101 3 t. 619.550.1355 4 e. [email protected] 5 John J. O’Brien (State Bar No. 253392) THE O’BRIEN LAW FIRM, APLC 6 750 B Street, Suite 3300 San Diego, CA 92101 7 t. 619.535.5151 8 e. [email protected] 9 Brian M. Holm (State Bar No. 255691) HOLM LAW GROUP, PC 10 12636 High Bluff Drive, Suite 400 San Diego, CA 92130 11 t. 858.707.5858 12 e. [email protected] 13 Attorneys for Plaintiffs 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO 16 17 18 19 20 21 22 23 24 25 26 27 JANE DOE NOS. 1 - 22, 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; M1M 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 - 550, inclusive, Defendants. LEAD CASE: Case No.: 37-2016-00019027-CU-FR-CTL CONSOLIDATED WITH: Case No.: 37-2017-00033321-CU-FR-CTL Case No.: 37-2017-00043712-CU-FR-CTL DECLARATION OF PLAINTIFF JANE DOE NO. 3 IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANT DOMI PUBLICATION LLC’S SPECIAL MOTION TO STRIKE [CCP §425.16] Date: Time: Judge: Location: August 31, 2018 9:00 a.m. Hon. Joel R. Wohlfeil C-73 28 DECLARATION OF JANE DOE NO. 3 DocuSign Envelope ID: DC858224-68CF-408D-9FF8-4AAF8721E1A1 2 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 I, Jane Doe No. 3, declare as follows: 1. I am a plaintiff in the above-captioned action: I have personal knowledge of each fact stated in this declaration. 2. In March 2014, Defendants contacted me on ExploreTalent.com, seeking young women for modeling. I eventually responded and corresponded with defendant Andre Garcia ("GARCIA") (then going by his alias "Jonathan"). Our initial conversions were via text and/or email -- the following representations regarding distribution were conveniently by phone or in-person. 3. GARCIA told me that Defendants would not post the subject video online and they would not distribute the video in the United States. GARCIA told me the video would go overseas to South America - and would only be in DVD format. 4. Before the shoot, GARCIA and defendant Matthew Wolfe ("WOLFE") (going by his alias "Ben"), again, assured me they would not post the video online and they would not distribute the video in the United States. They assured me there was nothing to worry about, promised me privacy, and represented nobody I knew would see the videos. 5. WOLFE and GARCIA continued to make the above representations before and simultaneous with providing me documents to sign. They also told the documents were merely to ensure my privacy and that I would be compensated. 6. In July 2014, Defendants released my video on their website, www.girisdopom.com, and other websites, which were then discovered by my friends, coworkers, employer, and my family. 7. As a result of the release of the video, I have suffered emotional distress damages (including loss of eating, loss of sleep, enduring fright, shock, nervousness, anxiety, depression, embarrassment, mortification, shame, and fear): a. I have suffered on an almost daily basis. b. I have had to tell boyfriends, which has resulted in breakups and pain. c. I was shunned by friends and coworkers. 28 DECLARATION OF JANE DOE NO. 3 DocuSign Envelope ID: DC858224-68CF-408D-9FF8-4AAF8721 E1 A 1 d. I have been harassed on social media -:- to the point where I had to change usernames and 2 3 block strangers. e. A fonner friend blackmailed me after finding the video, suggesting he would further 4 5 spread the video, unless I had sex with him. f. 6 7 current or future employers/coworkers will discover the video. g. I am also terrified that I will not be admitted into future colleges, to which I am now 8 9 I was so humiliated at work that I had to leave my job. I am also terrified that any applying. b. I have gone through hours of therapy. 10 1. I have had to speak with family about this, which bas caused me shame and humiliation. l1 J. This incident has denigrated by confidence and well-being. I have intermittent anxiety 12 and social issues. I am paranoid and afraid of people discovering the video and thus I 13 distance myself from others. 14 8. I would never have agreed to the video, if Defendants had been truthful, told me their plan to 15 release my video on their website, or told me l was in danger. I would never have agreed to the 16 video, if Defendants had told me their website existed. I made a mistake trusting the 17 Defendants - they are not truthful people. 18 9. Before and during this lawsuit, I made changes to my life to minimize the harassment and other 19 damages the Defendants have caused me. In this lawsuit, 1 seek the Court's help in remedying 20 the.damages the Defendants have caused me. Unsealing the Court record will likely cause me 21 even more harm and the harassment may exacerbate and/or resurface. Unsealing the Court 22 record will worsen the very hann I have am seeking to now xemedy. 23 24 25 26 27 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: March 1, 20 I 7 �· . I+, .. ,1•:i \)11a,l l,y By: 1111J11 Vr,r :. ·• -·· ,,,;..,,or.•1 11:.i Jane Doe No. 3 28 DECLARATION OF JANE DOE NO. 3