Paul Andrew Mitchell, Sui Juris
c/o Forwarding Agent at:
11230 Gold Express Dr., #310-188
Gold River 95670-4484
CALIFORNIA, USA
In Propria Persona
All Rights Reserved
without Prejudice
District Court of the United States
Eastern Judicial District of California
Paul Andrew Mitchell, ) #CIV. S-01-1480 WBS DAD PS
)
Plaintiff, ) FIRST SUPPLEMENT TO
) VERIFIED COMPLAINT FOR
v. ) DAMAGES AND INJUNCTION
) FOR COPYRIGHT INFRINGEMENT
AOL Time Warner, Inc., ) AND RELATED CLAIMS:
Steve Case, )
Lennert Leader, ) JURY DEMANDED
Randall J. Boe, )
Adit Seth, )
George R. Boyce, )
James R. Bramson, )
Daniel Levy, )
Jonathan Steuer, )
Brian Oblivion, )
Donald D. Hoffman, )
Karl Kleinpaste, )
California Institute of Technology, )
Cornell University, )
Embry-Riddle Aeronautical University, )
Florida Institute of Technology, )
Indiana University, )
Miami University of Ohio, )
Northeastern University, )
Pennsylvania State University, )
Princeton University, )
Stanford University, )
Stetson University, )
Swiss Federal Institute of Technology,)
University of Arkansas, )
University of California, )
University of Georgia, ) [continue next page:]
University of Kansas, )
University of Michigan, )
University of Oregon, )
University of Texas, and )
--------------------------------------)
James Daugherty-AA Research, )
Internet Domain INCORPTEK.COM, )
Justsystem Pittsburgh Research Center,)
Midwest Internet Exchange, Inc., [sic])
Internet Domain NEBONET.COM, )
Simple Network Communications, Inc., )
Snow Hill Enterprises, Inc., ) [continue next page:]
Luke Stevens, )
COWZ Technologies, )
The Works BBS, and )
Doe’s 61 thru 2,500, )
)
Defendants. )
______________________________________)
Page
VERIFIED CRIMINAL COMPLAINTS 6
VERIFICATION 51
After a careful assessment of all electronic evidence in His possession, Plaintiff now supplements the Initial COMPLAINT within the period allowed for amending complaints without leave of the Court.
This FIRST SUPPLEMENT makes no changes to the Initial COMPLAINT; it simply adds further facts and evidence, and names further Defendants, as revealed by Plaintiff’s careful assessment of all electronic evidence in His possession. That assessment was performed during the period between August 2000 A.D. and April 2001 A.D.
The types and amounts of electronic evidence necessarily vary from one Internet domain to another. The criminal retaliation of which Plaintiff complains, specifically in COUNTS THREE and FOUR of the Initial COMPLAINT, caused Plaintiff to be separated from His personal computer for extended periods of time. For example, see Exhibit D-37. That retaliation also made it impossible for Plaintiff to afford the telephone and subscription fees of a private Internet connection during periods when He was not separated from His computer.
Although it was possible to perform extensive copyright enforcement in many public places, such as the local area networks at Southwest Texas State University and Kinko’s, Plaintiff was prevented from saving electronic evidence to disk drives on those networks.
The volume and complexity of evidence to be archived exceeded the storage capacity of multiple 1.44 megabyte floppy disks -– the only removable medium available on most of those computers. Fortunately, some email correspondence was able to be archived on the Internet, using free email services; other correspondence was destroyed when certain free services were suspended. See Exhibits D-21-A and D-21-B.
Like any large database, the electronic evidence now assembled in the instant case is not perfect, nor as complete as it could have been under better circumstances. Remember that Plaintiff has not been compensated for any of the research and writing now evident in the Initial COMPLAINT, in this SUPPLEMENT, and in all related Exhibits.
Plaintiff submits that these 2 pleadings and related Exhibits are the best of which He was capable, given the nearly continuous barrage of severe financial hardship, personal injury and related torts that Plaintiff was forced to suffer at the hands of all named Defendants.
Utilizing the sorted sequence of Internet domains as found in the Master List of Principal Violations at Exhibit D-43, Plaintiff now formally names additional Defendants as Proper Parties by substituting their proper names, respectively, for a subset of the John Doe’s as found on the caption page of the Initial COMPLAINT:
Doe #1 is now Barrett Owens.
Doe #2 is now A2Z Computers & Software.
Doe #3 is now James H. Daugherty.
Doe #4 is now James Daugherty-AA Research.
Doe #5 is now Internet Domain ALGONET.SE.
Doe #6 is now Mark Creamer.
Doe #7 is now Internet Domain BAYON.NET.
Doe #8 is now Christopher Kankel.
Doe #9 is now C I Host.
Doe #10 is now Desert Video Production.
Doe #11 is now Cyborganic Media.
Doe #12 is now Alias “Dimitri”.
Doe #13 is now Carrie Malcolm.
Doe #14 is now Internet Domain DEOXY.ORG.
Doe #15 is now David W. Starr.
Doe #16 is now ALH.
Doe #17 is now Mitchell A. Goodkin.
Doe #18 is now Image’FX Productions, Inc.
Doe #19 is now EZ2 Network, Inc.
Doe #20 is now Cybergate, Inc.
Doe #21 is now Josh Bempechat.
Doe #22 is now Earthlink Network, Inc.
Doe #23 is now Hacked Archives [sic].
Doe #24 is now Internet Domain INCORPTEK.COM.
Doe #25 is now Telecode.
Doe #26 is now InfoMagic, Inc.
Doe #27 is now Joe Szemiot.
Doe #28 is now Intac Access Corporation.
Doe #29 is now Internet Online Services.
Doe #30 is now Justsystem Pittsburgh Research Center.
Doe #31 is now Leander Pearson.
Doe #32 is now Burntfork Rural Systems.
Doe #33 is now X Mission.
Doe #34 is now L0pht Heavy Industries.
Doe #35 is now Levity.
Doe #36 is now Club Madness.
Doe #37 is now Maui Global Communications.
Doe #38 is now David Feustel.
Doe #39 is now Midwest Internet Exchange, Inc.
Doe #40 is now Jeff Head.
Doe #41 is now Internet Domain NEBONET.COM.
Doe #42 is now Kearney, Castillo & Blake.
Doe #43 is now Phreak Network Solutions.
Doe #44 is now J. Wyatt.
Doe #45 is now Primenet.
Doe #46 is now Mike McArthur.
Doe #47 is now Provide Net.
Doe #48 is now Simple Network Communications, Inc.
Doe #49 is now Snow Hill Enterprises, Inc.
Doe #50 is now Dave Alexander.
Doe #51 is now John L. Dortch.
Doe #52 is now Telalink Corporation.
Doe #53 is now Thomson Financial Services.
Doe #54 is now Transworld Mail Express.
Doe #55 is now Jahred Held.
Doe #56 is now Westworld Communications.
Doe #57 is now Luke Stevens.
Doe #58 is now Msen, Inc.
Doe #59 is now COWZ Technologies.
Doe #60 is now The Works BBS.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Barrett Owens and served same on the Federal Bureau of Investigation (“FBI”) in Memphis, Tennessee. (See Domain A2ZNET.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Barrett Owens is attached as Exhibit F‑1.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant James H. Daugherty and served same on the FBI in Detroit, Michigan. (See Domain A-ALBIONIC.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant James H. Daugherty is attached as Exhibit F‑2.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Steve Case, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Steve Case is attached as Exhibit F‑3.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Lennert Leader, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Lennert Leader is attached as Exhibit F‑4.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Randall J. Boe, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Randall J. Boe is attached as Exhibit F‑5.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Adit Seth, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Adit Seth is attached as Exhibit F‑6.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant George R. Boyce, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant George R. Boyce is attached as Exhibit F‑7.
On April 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant James R. Bramson, and served same on the FBI in Richmond, Virginia. (See Domain AOL.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant James R. Bramson is attached as Exhibit F‑8.
On February 4, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Mark Creamer and served same on the FBI in New York City. (See Domain BAYON.NET.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Mark Creamer is attached as Exhibit F‑9.
On February 4, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Christopher Kankel and served same on the FBI in Los Angeles, California. (See Domain CALTECH.EDU.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Christopher Kankel is attached as Exhibit F‑10.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Carrie Malcolm and served same on the FBI in New York City. (See Domain DEOXY.ORG.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Carrie Malcolm is attached as Exhibit F‑11.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Alias “Dimitri” and served same on the FBI in New York City. (See Domain DEOXY.ORG.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Alias “Dimitri” is attached as Exhibit F‑12.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant David W. Starr, and served same on the FBI in Los Angeles, California. (See Domain ETEXT.ORG.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant David W. Starr is attached as Exhibit F‑13.
On February 4, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Josh Bempechat, and served same on the FBI in Los Angeles, California. (See Domain FREEDOMDOMAIN.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Josh Bempechat is attached as Exhibit F‑14.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant David Feustel and served same on the FBI in Fort Wayne, Indiana. (See Domain MIXI.NET.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant David Feustel is attached as Exhibit F‑15.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Jeff Head and served same on the FBI in Salt Lake City, Utah. (See Domain NEBONET.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Jeff Head is attached as Exhibit F‑16.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Mike McArthur and served same on the FBI in Detroit, Michigan. (See Domain PROVIDE.NET.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Mike McArthur is attached as Exhibit F‑17.
On March 7, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant John L. Dortch and served same on the FBI in Memphis, Tennessee. (See Domain TELALINK.NET.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant John L. Dortch is attached as Exhibit F‑18.
On February 4, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Jahred Held and served same on the FBI in Los Angeles, California. (See Domain WESTWORLD.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Jahred Held is attached as Exhibit F‑19.
On April 23, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Alias “Dimitri” and served same on the FBI in New York City. (See Domain INTAC.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Alias “Dimitri” is attached as Exhibit F‑20.
On April 23, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Alias “Dimitri” and served same on the FBI in San Francisco, California. (See Domain CYBORGANIC.COM.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Alias “Dimitri” is attached as Exhibit F‑21.
On April 23, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Alias “Dimitri” and served same on the FBI in Fort Wayne, Indiana. (See Domain MIXI.NET.)
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Alias “Dimitri” is attached as Exhibit F‑22.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Barrett Owens at Defendant A2Z Computers & Software, P.O. Box 906, Collierville 38027‑0906, TENNESSEE, USA. (See Domain A2ZNET.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Barrett Owens supra, is attached as Exhibit G‑1.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant James H. Daugherty at Defendant James Daugherty‑AA Research, P.O. Box 20273, Ferndale 48220‑0273, MICHIGAN, USA. (See Domain A‑ALBIONIC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant James H. Daugherty supra, is attached as Exhibit G‑2.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the Chief Executive Officer (“CEO”) at Defendant Internet Domain ALGONET.SE, P.O. Box 1160, Stockholm 111 91, SWEDEN. (See Domain ALGONET.SE.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Internet Domain ALGONET.SE, is attached as Exhibit G‑3.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Steve Case, CEO of Defendant AOL (“Defendant AOL”). (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Steve Case supra, is attached as Exhibit G‑4.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Lennert Leader, Chief Financial Officer at Defendant AOL. (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Lennert Leader supra, is attached as Exhibit G‑5.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Randall J. Boe, Associate General Counsel at Defendant AOL. (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Randall J. Boe supra, is attached as Exhibit G‑6.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Adit Seth, Legal Intern at Defendant AOL. (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Adit Seth supra, is attached as Exhibit G‑7.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant George R. Boyce, Internet Contact at Defendant AOL. (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant George R. Boyce supra, is attached as Exhibit G‑8.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant James R. Bramson, Designated Agent at Defendant AOL. (See Domain AOL.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant James R. Bramson supra, is attached as Exhibit G‑9.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Mark Creamer, c/o the CEO at Defendant Internet Domain BAYON.NET, 253 Vestal Parkway East, Vestal 13850, NEW YORK STATE, USA. (See Domain BAYON.NET.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Mark Creamer supra, is attached as Exhibit G‑10.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Christopher Kankel, c/o Mr. David Baltimore, President of Defendant California Institute of Technology, 1200 East California Boulevard, Pasadena 91125, CALIFORNIA, USA. (See Domain CALTECH.EDU.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Christopher Kankel supra, is attached as Exhibit G‑11.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant C I Host, 1851 Central Drive, #110, Bedford 76021, TEXAS, USA. (See Domain CIHOST.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant C I Host supra, is attached as Exhibit G‑12.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Desert Video Production, P.O. Box 6426, Yuma 85366, ARIZONA, USA. (See Domain CINECAM.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Desert Video Production supra, is attached as Exhibit G‑13.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Karl Kleinpaste, c/o Office of the President at Defendant Carnegie Mellon University, 5000 Forbes Avenue, Pittsburgh 15213, PENNSYLVANIA, USA. (See Domain CMU.EDU.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Karl Kleinpaste supra, is attached as Exhibit G‑14.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant James H. Daugherty, c/o the University President, Office of the President at Defendant Cornell University, Ithaca 14853, NEW YORK STATE, USA. (See Domain CORNELL.EDU.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant James H. Daugherty supra, is attached as Exhibit G‑15.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Jonathan Steuer, Technical Contact at Defendant Cyborganic Media, 2261 Market Street, Suite 100, San Francisco 94114, CALIFORNIA, USA. (See Domain CYBORGANIC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Jonathan Steuer supra, is attached as Exhibit G‑16.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Alias “Dimitri”, c/o Defendant Cyborganic Media, 2261 Market Street, Suite 100, San Francisco 94114, CALIFORNIA, USA. (See Domain CYBORGANIC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Alias “Dimitri” supra, is attached as Exhibit G‑17.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendants Daniel Levy and Carrie Malcolm at Defendant Levity [sic], P.O. Box 1013, Cooper Station, New York 10276‑1013, NEW YORK STATE, USA. (See Domain DEOXY.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendants Daniel Levy and Carrie Malcolm supra, is attached as Exhibit G‑18.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Alias “Dimitri”, c/o Defendant Internet Domain DEOXY.ORG, P.O. Box 1013, Cooper Station, New York 10276‑1013, NEW YORK STATE, USA. (See Domain DEOXY.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Alias “Dimitri” supra, is attached as Exhibit G‑19.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant David W. Starr, dba Defendant ALH, 9016 Wilshire Boulevard, #231, Beverly Hills, CALIFORNIA, USA. (See Domain ETEXT.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant David W. Starr supra, is attached as Exhibit G‑20.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Mitchell A. Goodkin, Esq. [sic], P.E., Intellectual Property Counsel, Sr. Technology Licensing Specialist, Office of the Vice President and General Counsel at Defendant University of Michigan, Ann Arbor 48109, MICHIGAN, USA. (See Domain ETEXT.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Mitchell A. Goodkin, Esq. [sic], P.E. supra, is attached as Exhibit G‑21.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Image’FX Productions, Inc., 10 Fiske Place, Suite 233, Mount Vernon 10550, NEW YORK STATE, USA. (See Domain EXECNET.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Image’FX Productions, Inc. supra, is attached as Exhibit G‑22.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant EZ2 Network, Inc., 41811 Ivy Street, Suite “B”, Murietta 92562, CALIFORNIA, USA. (See Domain EZ2NET.NET.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant EZ2 Network, Inc. supra, is attached as Exhibit G‑23.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Cybergate, Inc., dba Channel 1 Communications, 1030 Massachusetts Avenue, Cambridge 02138, MASSACHUSETTS, USA. (See Domain FILELIBRARY.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Cybergate, Inc. supra, is attached as Exhibit G‑24.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Josh Bempechat, 6056 Woodman Avenue, Van Nuys 91401, CALIFORNIA, USA. (See Domain FREEDOMDOMAIN.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Josh Bempechat supra, is attached as Exhibit G‑25.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Earthlink Network, Inc., 1430 W. Peachtree St., N.W., Suite 400, Atlanta 30309, GEORGIA, USA. (See Domain FREEDOMDOMAIN.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Earthlink Network, Inc. supra, is attached as Exhibit G‑26.
On March 7, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Josh Bempechat, c/o 484 Lake Park Avenue, #81, Oakland 94610, CALIFORNIA, USA. (See Domain FREEDOMDOMAIN.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Josh Bempechat supra, is attached as Exhibit G‑27.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Hacked Archives [sic], P.O. Box 911, Abbingdon 24212, VIRGINIA, USA. (See Domain HACKEDARCHIVES.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Hacked Archives supra, is attached as Exhibit G‑28.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Internet Domain INCORPTEK.COM, 625 – 31st Avenue North, #J‑90, Columbus 39705‑1858, MISSISSIPPI, USA. (See Domain HACKEDARCHIVES.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Internet Domain INCORPTEK.COM supra, is attached as Exhibit G‑29.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Telecode, P.O. Box 6426, Yuma 85366‑6426, ARIZONA, USA. (See Domain HACKERSCATALOG.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Telecode supra, is attached as Exhibit G‑30.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Christopher Kankel, c/o Office of the President at Defendant Indiana University, Bloomington 47405, INDIANA, USA. (See Domain INDIANA.EDU.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Christopher Kankel supra, is attached as Exhibit G‑31.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant InfoMagic, Inc., 11950 North Highway 89, Flagstaff 86004, ARIZONA, USA. (See Domain INFOMAGIC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant InfoMagic, Inc. supra, is attached as Exhibit G‑32.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Joe Szemiot at Defendant INTAC Access Corporation, 256 Broad Avenue, Palisades Park 07650, NEW JERSEY, USA. (See Domain INTAC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Joe Szemiot supra, is attached as Exhibit G‑33.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Alias “Dimitri”, c/o Defendant INTAC Access Corporation, 256 Broad Avenue, Palisades Park 07650, NEW JERSEY, USA. (See Domain INTAC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Alias “Dimitri” supra, is attached as Exhibit G‑34.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Internet Online Services, 294 State Street, Hackensack 07601, NEW JERSEY, USA. (See Domain IOS.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Internet Online Services supra, is attached as Exhibit G‑35.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Karl Kleinpaste, c/o the CEO at Defendant Justsystem Pittsburgh Research Center, 4616 Henry Street, Pittsburgh 15213, PENNSYLVANIA, USA. (See Domain JPRC.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Karl Kleinpaste supra, is attached as Exhibit G‑36.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Leander Pearson at Defendant Burntfork Rural Systems, P.O. Box 2933, Burntfork 82938, WYOMING, USA. (See Domain KINGDOMOFZION.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Leander Pearson supra, is attached as Exhibit G‑37.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant X Mission, 51 East 400 South, #200, Salt Lake City 84111, UTAH, USA. (See Domain KINGDOMOFZION.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant X Mission supra, is attached as Exhibit G‑38.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Brian Oblivion, c/o the CEO at Defendant L0pht Heavy Industries, P.O. Box 990857, Boston 02199, MASSACHUSETTS, USA. (See Domain L0PHT.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Brian Oblivion supra, is attached as Exhibit G‑39.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Daniel Levy at Defendant Levity [sic], P.O. Box 1013, Cooper Station, New York 10276‑1013, NEW YORK STATE, USA. (See Domain LEVITY.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Daniel Levy supra, is attached as Exhibit G‑40.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Carrie Malcolm at Defendant Levity [sic], P.O. Box 1013, Cooper Station, New York 10276‑1013, NEW YORK STATE, USA. (See Domain LEVITY.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Carrie Malcolm supra, is attached as Exhibit G‑41.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Alias “Dimitri”, c/o Defendant Levity [sic], P.O. Box 1013, Cooper Station, New York 10276‑1013, NEW YORK STATE, USA. (See Domain LEVITY.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Alias “Dimitri” supra, is attached as Exhibit G‑42.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Club Madness [sic], 11 Stanford Road, Unionville, Ontario L3R 6L8, CANADA. (See Domain MADNESS.ORG.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Club Madness [sic], is attached as Exhibit G‑43.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Maui Global Communications, 590 Lipoa Parkway, #266, Kihei 96753, HAWAII, USA. (See Domain MAUI.NET.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Maui Global Communications supra, is attached as Exhibit G‑44.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant David Feustel, c/o the CEO at TEK Interactive Systems (formerly Defendant Midwest Internet Exchange, Inc. [sic]), P.O. Box 8368, Fort Wayne 46808, INDIANA, USA. (See Domain MIXI.NET.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant David Feustel supra, is attached as Exhibit G‑45.
On April 11, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Alias “Dimitri”, c/o the CEO at TEK Interactive Group, Inc. (formerly Defendant Midwest Internet Exchange, Inc. [sic]), P.O. Box 8368, Fort Wayne 46808, INDIANA, USA. (See Domain MIXI.NET.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Alias “Dimitri” supra, is attached as Exhibit G‑46.
On March 5, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant Jeff Head, c/o the CEO at Defendant Internet Domain NEBONET.COM, 656 North Main, Nephi, UTAH, USA. (See Domain NEBONET.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant Jeff Head supra, is attached as Exhibit G‑47.