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Filing # 94717000 E-Filed 08/23/2019 06:46:34 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MOBOOKA, LLC., CIRCUIT CIVIL DIVISION
a Florida limited liability company, _
Plaintiff, CASE NO.: 2017-CA-004043
v.
JOHN HANCOCK, individually,
FORSA LLC, a Wyoming limited liability
company,
Defendant.
PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT
ON COUNT III OF THE COMPLAINT AND MEMORANDUM OF LAW
COMES NOW, the Plaintiff, MOBOOKA, LLC. (‘Plaintiff’), by and through the’
undersigned counsel, moves this court for an order pursuant to Fla. R. Civ. P. 1.510, granting
Partial Summary Judgment against JOHN HANCOCK (“Defendant”), with respect to Count III
of the Plaintiffs Second Amended Complaint and states as follows:
PROCEDURAL BACKGROUND
1. On May 1*, 2017, the instant case was filed.
2. On June 6", 2018 and July 20", 2018, respectively, Plaintiff's Amended and Second
Complaints were filed.
3. On October 25", 2018, this Court entered default against FORSA LLC (“FORSA”).
4. On February 7", 2019, this Court entered a final judgment in default against FORSA, as
follows:
“Plaintiff MOBOOKA LLC shall recover from FORSA LLC, the amount of Three
Hundred Forty-Three Thousand Seven Hundred Dollars ($343,782.00), which sum
shall bear interest rate of 6.33% per annum from the date of this Final
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comJudgment...Plaintiff is entitled to its reasonable attorney’s fees and taxable costs
and the court retains jurisdiction to determine the reasonableness thereof.”
5. Defendant’s Answer to Plaintiff's Second Amended Complaint was filed on April 12",
2019; which consisted of a general denial of all counts, and no affirmative defenses.
6. Plaintiff now moves for Partial Summary Judgment against Defendant John Hancock, on
Count III of its Second Amended Complaint — Civil Theft.
FACTUAL BACKGROUND
7. Plaintiff is a marketing and advertising agency specializing in affiliate marketing, mobile
and online advertising, and search engine marketing.
8. The commercial name of Plaintiff is Convert2Media.
9. Defendant was employed by Plaintiff as an Internal Redirect Manager, whose primary
function was to manage redirect traffic for several advertising and marketing networks, including
for Plaintiff.
10. On or about April 13, 2017, a competitor network, discovered suspicious traffic redirects
from Plaintiff to the competitor from an unknown network affiliate, FORSA.
11. Upon further investigation, it was discovered that Defendant was redirecting traffic
generated by Plaintiff to FORSA, which generated $114,594.00 in revenue for FORSA.
12. Furthermore, the revenue generated by Defendant from redirecting Plaintiff’s traffic to
FORSA was deposited to FORSA and Defendant’s accounts =! and
at CHASE BANK. Defendant is also the accountholder for the HE account at CHASE
BANK where the redirect revenues were being paid to.
13. When Plaintiff confronted Defendant of the discrepancy regarding Plaintiff ‘s traffic being
tedirected to FORSA, Defendant confessed to Plaintiff of his actions and promised to pay back
Plaintiff the revenue generated by Defendant by redirecting Plaintiff ‘s traffic to FORSA.
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 * T: (786) 837-6787 F: (305) 718-0687 * www.epgdlaw.com14. To this date, Defendant has made no attempts to refund or return the sum of $114,594.00
to Plaintiff.
15. As a result of Defendant’s actions, Plaintiff has suffered damages.
STATEMENT OF UNDISPUTED FACTS
16. Defendant has admitted that he was an employee of Convert2Media, and not Mobooka, on
the dates of the incidents that give rise to this cause of action (Dec. 2016 - Apr. 2017). See Exhibit
A - Deposition of John Gant Hancock, page 11, paragraphs 5-6:
5 Q. “And when did you work for Convert2Media?”
6A. “I believe it was March 2015 to April 2017.”
17. Defendant has admitted that he created FORSA, on or about December 2016, while he was
an employee at Convert2Media - See Exhibit A at page 36, paragraphs 3-7; page 58, paragraphs
3-6:
3 Q “Now, at the same time you were working for Convert2Media you created
Forsa LLC in Wyoming around that same time, right?”
7A. “Yes.”
3Q “[DJid you create Forsa around December of 2016?
5A. “I -- that -- | believe so. It sounds right around the correct timing.”
18. Defendant has admitted that the only other individual who appears as agent of FORSA,
Mr. Nathan Bennett, was merely hired to file the incorporation documents of FORSA, and has no
other involvement in the company other than as Registered Agent. See Exhibit A at pages 68,
paragraphs 20-25; page 69, paragraphs 1-4:
20 Q. “Does Forsa's registered agent that you were talking about before know
anything about what Forsa does or -- do they know anything about what Forsa
are would guess not. | don't recall ever having to explain.”
25 Q. “They're just the registered agent?”
1A. “Yes.”
2 Q. Okay. So, you don't work with them or anything like that?”
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com4A. “I don't even know who they are. It's an online forum, and you pay with PayPal
or something like that.”
19. Defendant has admitted that he in fact redirected traffic from Mobooka to other networks,
with the intent of excluding Mobooka from the benefit of the business obtained by that traffic. See
Exhibit B — iMessage Conversation between John Hancock — Steve Howe:
“You're saying | went into Walmart and took money from the safe. A more accurate
accusation would be that | stood outside and sent customers to [TJarget. | don’t
even need to have this argument, | already agreed to make it right.
20. Defendant has admitted that by redirecting traffic outside of his Mobooka’s network,
thereby denying Mobooka’s earning, he committed a crime. See Exhibit B:
“Well, | definitely don’t feel good about what happened, regardless of which crime
was committed”.
21. Defendant has admitted that he did not have independent access to the affiliate links he
tedirected to Mobooka’s competitor’s, other than the access he obtained as an employee of
Convert2Media. See Exhibit A at page 37, paragraphs 8-22; page 38, paragraphs 1-4:
8 Q. “But how did you buy from them then if you didn't know their names or the
contacts or anything like that?”
11 A. “l was given links by the networks. That's what the networks do.”
22 A. “When | was working for Convert2Media, | was told by the sales staff, really
just Steve Howe, which products should be sold. | did not know who owned
them. | wasn't in contact with those people. | was just given what's called an
affiliate link and told run this. And | would then go and market an affiliate link that
would link to an advertiser's sales page hosted on Convert2Media's network.
That's how it works.”
22. Defendant has admitted that, while he was a buyer for Covert2Media, he acted as a buyer
on behalf of any other companies, mainly his Company, FORSA. See Exhibit A at page 31,
paragraphs 10-15:
10 Q “Did you ever act as a buyer on behalf of any other companies while you
were working for Convert2Media?”
13 A “Yes.”
14 Q. "Which companies?”
15 A. “My company, Forsa.”
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com23 Defendant has admitted that, as an employee of Convert2Media, he was a buyer who
worked with advertisers.
24 Defendant also admitted that, while an employee of Convert2Media, he created FORSA
while at the same time, he was working for FORSA, for the benefit of FORSA, working as a
buyer. See Exhibit A at page 34, paragraphs 18-23:
18 Q. “Okay, but you're working at Convert2Media; you're a buyer working with
the advertisers, right?
20 A. “Right.”
21 Q. “How do these -- you're also working for Forsa or for the benefit of Forsa?
23 A. Right.
25 Defendant has admitted that the networks he worked with, on behalf of his company
FORSA, were competitors of Convert2Media. Defendant also admitted that, as buyer for FORSA,
he purchased media on these advertising networks' behalf, to advertise; and as a result, the
commissions received from these activities, were paid to FORSA. See Exhibit A at page 36,
paragraphs 3-24:
3 Q. “Okay. So, we're on the same page there. Now, at the same time you were
working for Convert2Media you created Forsa LLC in Wyoming around that same
time, right?”
7A. “Yes.”
8 Q. “Okay. Now, Forsa LLC -- now, for Forsa LLC you would be a buyer as
well?”
10 A. “Yes.”
11 Q. “Okay. But you're saying you were working with advertising networks?”
13 A. “Right.”
14 Q. “So, these advertising networks were they competitors to Convert2Media?”
16 A. “Yes.”
17 Q. “And you bought on these advertising networks’ behalf?”
19 A. “Right.”
20 Q. “To advertise?”
21 A. “Correct, yes.”
22 Q. “And the commissions you got would be paid to you directly or to Forsa?”
24 A. “On -- Forsa.”
26 Defendant has admitted that his other fellow employees at Convert2Media worked “side
jobs” while working at Convert2Media, and these fellow employees paid commission percentages
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comto Convert2Media, via Mr. Steve Howe, on said “side jobs”. Defendant further admitted that he in
fact did not pay Mr. Howe or Convert 2Media any commission percentages from his “side job” at
FORSA. See Exhibit A at page 52, paragraphs 20-25; page 53, paragraphs 1-5:
20 Q. “Did anybody else have side jobs while working there?”
22 A. “Yes.”
23 Q. “Did they pay Convert2Media the 10 percent or whatever it was?”
25 A. “They paid Steve Howe directly, yes.”
1 Q. “But you didn't?”
2A. “No, | did not.”
3 Q. “And did you know these people paid Steve Howe directly from the time you
were working there?”
5A. “Yes.”
27 Defendant has admitted that Mobooka did not authorize him to redirect traffic to other
entities. See Exhibit C — Defendant’s Response to Plaintiff's Requests for Admission #7.
RFA #7 — “Admit Mobooka did not authorize you to redirect traffic to other
entities.”
Response #7: “Admit”
28 Defendant has admitted that he created FORSA to anonymously run traffic on behalf of a
network other than the one at which he was employed. See Exhibit D — Defendant’s Response to
Plaintiff’s Interrogatories #9:
“| created Forsa to anonymously run traffic on behalf of a network other than the
one at which | was employed.”
29 It is irrefutable that the proceeds of generated from the redirecting of traffic caused by
Defendant, were deposited in the Chase Bank account owned by FORSA. See Exhibit B - Chart
of Payments within iMessage Conversation.
30 It is irrefutable that Defendant, as an employee who managed Convert2Media’s internal
redirect traffic, created his own company and proceeded to redirect Mobooka’s internal redirect
traffic to a competitor under his own corporation. It is also irrefutable that Defendant verbally
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comadmitted to stealing this traffic and receiving payment under his own LLC. See Exhibit E - Ocoee
Police Report.
31 Itis irrefutable that Defendant, on April 13, 2019, visited the residence of C2M’s partner,
Mr. Steve Howe, and admitted his wrongdoing. See Exhibit E - Ocoee Police Report; Exhibit F
— WhatsApp Messages (Steve Howe — Johnathan Cole).
MEMORANDUM OF LAW
L Motion for Summary Judgment
32 Summary judgment is proper where “the pleadings, depositions, answers to
interrogatories, and admissions on file together with the affidavits, if any, show that there is no
genuine issue as to any material fact and that the moving party is entitled to judgment as a matter
of law.” Fla. R. Civ. P. 1.510 (c); Emile v. First Nat'l Bank of Miami, 126 So. 2d 305,306 (Fla. 3d
DCA 1961).
33 Once the moving party meets this burden in demonstrating that there is no genuine issue
of material fact and that it is entitled to judgment as a matter of law, the party opposing entry of
summary judgment must prove the existence of genuine triable issues. First North American Nat.
Bank v. Hummel, 825 So.2d 502, 503 (Fla. 2d DCA 2002).
34 The opposing party must demonstrate the existence of genuine issues of material fact by
pointing to countervailing facts or justifiable inferences to be drawn from those facts; a mere denial
of the allegations of the complaint is insufficient to show the non-existence of a material issue.
Dozier & Gay Paint Co., Inc. v. Dilley, 518 So. 2d 946, 948 (Fla. 1st DCA 1988);
35 Mere existence of a dispute as to matters not material to the action will not preclude entry
of summary judgment. Armstrong v. Southern Bell Tel. & Tel. Co., 366 So. 2d 88, 90 (Fla. Ist
DCA 1987).
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com36 For purposes of summary judgment, a “material fact” is a fact that is essential to the
resolution of legal questions raised in the case. Florida Dep't. Of Envtl. Reg. v. C.P. Developers,
Inc., 512 So. 2d 258, 261 (Fla. 1st DCA 1987).
37 “Although it is true that, generally, fact issues relating to intent do not lend themselves to
summary judgment, summary judgment is not precluded simply because the action involves an
issue of intent.” Fleming v. Peoples First Fin. Sav. & Loan Ass'n, 667 So. 2d 273, 274 (Fla. Ist
DCA 1995)
I. Civil Theft Under Fla. Stat. §772.11
38 Fla. Stat. §772.11 provides as follows: “Any person who proves by clear and convincing
evidence that he or she has been injured in any fashion by reason of any violation of ss. 812.012-
812.037 or s. 825.103(1) has a cause of action for threefold the actual damages sustained and, in
any such action, is entitled to minimum damages in the amount of $200, and reasonable attorney's
fees and court costs in the trial and appellate courts.”
39 Florida Statutes, § 812.014 sets forth theft as follows: “(1) A person commits theft if he or
she knowingly obtains or uses, or endeavors to obtain or to use, the property of another with intent
to, either temporarily or permanently: (a) Deprive the other person of a right to the property or a
benefit from the property. (b) Appropriate the property to his or her own use or to the use of any
person not entitled to the use of the property.”
40 To establish a claim for civil theft, a party must prove that a conversion has taken place
and that the accused party has acted with criminal intent. Holland v. McCullen, 764 So.2d 810
(Fla. 2d DCA 2000).
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com41 In order to properly allege the element of criminal intent with respect to the crime of theft,
it need only be shown that the perpetrator in question had the intent to either temporarily or
permanently deprive the victim of property. Daniels v. State, 570 So.2d 319 (Fla. 2d DCA 1990).
42 Intent, being a state of mind, is often not subject to direct proof and can only be inferred
from circumstances.” Segal v. State, 98 So. 3d 739, 743 (Fla. 4th DCA 2012).
43 The standard for clear and convincing evidence requires that the evidence must be of such
weight that it produces in the mind of the trier of fact a firm belief or conviction, without hesitancy,
as to the truth of the allegations sought to be established.
LEGAL STANDARD AS APPLIED TO UNDISPUTED FACTS
44 There is no factual dispute that Defendant had no right or title of ownership to the affiliate
links he used to redirect marketing traffic away from Plaintiff.
45 There is no factual dispute that Defendant had no authorization to use the affiliate links
provided by Plaintiff in any way, other than at the direction and for the benefit of Plaintiff.
46 There is no factual dispute that Defendant knowingly redirected the marketing traffic to
which Plaintiff was entitled to, to other sources mainly Plaintiff's competitors, with the intent of
generating the income attributable from said traffic for himself, and thereby permanently depriving
Plaintiff of all the earnings associated from this traffic.
47 There is no factual dispute that Defendant engaged in said activity, with the intent of
benefiting himself personally.
48 There is no factual dispute that Defendant went to extreme lengths in furtherance of his
unlawful scheme; so much so, that he set up a shell corporation out of state, and proceeded to
create banking accounts for said corporation, for the sole purpose of depositing the earnings
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comwrongfully received by virtue of siphoning Plaintiff's traffic, in an attempt to conceal his activity,
in order to escape detection from Plaintiff.
49 There is no factual dispute that Defendant successfully carried out his scheme, depositing
hundreds of thousands of dollars belonging to Plaintiff, in the banking accounts he created
exclusively to carry out this scheme.
50 There is no factual dispute that Defendant admitted his wrongdoing to Plaintiff on several
occasions, and agreed to make things right with Plaintiff.
51 Furthermore, Defendant has not provided any evidence supporting his denial of Plaintiff's
allegations.
52 Thus, to the extent this Court enters a summary judgment on Plaintiff's Count III for Civil
Theft, Plaintiff is entitled to the reimbursement of the attorney's fees and costs expended in
prosecuting the above-styled Action.
53 Therefore, this Court should grant this Motion for Partial Summary Judgment as to Count
III for Civil Theft Pursuant to Florida Statute sec. 772.11.
CONCLUSION
54 Accordingly, there is no issue as to any material fact with respect to Count III of
PLAINTIFF’S Second Amended Complaint for Civil Theft and PLAINTIFF is entitled to a
judgment as a matter of law.
55 In light of Plaintiff's well-pled allegations and this instant Motion for Partial Final
Summary Judgment, the burden has shifted onto Defendant to produce evidence in order to defeat
said Motion.
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com56 The summary judgment evidence in this case conclusively demonstrates that there are no
genuine issues of material fact in this case, and Plaintiff is entitled to a judgment against Thorn as
a matter of law.
57 There are no genuine issues of material fact that Defendant knowingly and intentionally
committed civil theft under Florida law. Defendant’s intent is conclusive, demonstrated by his
elaborate scheme to hide his actions, along with his own statements that he took funds from
Plaintiff.
WHEREFORE Plaintiff respectfully requests this honorable Court to grant this Motion for
Partial Summary Judgment as to Count III (Civil Theft) of the Complaint, and any further relief
the Court deems appropriate.
EPGD ATTorRNEYS AT LAW, P.A.
ATTORNEYS FOR PLAINTIFF
777 SW 37" Ave., Ste. 510
Miami, Florida 33135
Tel: (786) 837-6787
Fax: (305) 718-0687
sam@epgdlaw.com
By: /s/ Samuel J Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
CERTIFICATE OF SERVICE
Thereby certify that a true and correct copy of the foregoing was furnished on this 23rd day’
of August, 2019 via Electronic Service and US Mail to John Hancock and FORSA LLC at
hancock.j.g@gmail.com, 5305 Lisa Ave Lakeland, FL 33813
By: /s/ Samuel J. Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 099778
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EPGD ATTORNEYS AT LAW, P.A.
777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comExhibit “A”oyoaouw 8 Wn KB
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John Hancock
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A. Before Branded Response, I was in consulting,
marketing consulting, in the affiliate marketing industry
as well as a campaign manager at a company called
Convert2Media which was an affiliate marketing network.
Q. And when did you work for Convert2Media?
A. I believe it was March 2015 to April 2017.
Q. And Convert2Media is related to -- how is that
related to Mobooka in your words?
A. I -- as far as I know, they share an owner.
Q. And what does your spouse do?
A. How is that relevant?
Q. The standard here is -- the legal standpoint is
anything that may lead to admissible evidence. I mean if
you had an attorney here --
A. I've been married since November 2017.
Q. Okay.
A. So, how is it relevant?
Q. I just wanted to know what your wife does. Do
you know what your wife does?
A. She's in marketing.
Q. Affiliate marketing?
A. No.
Q. What's your relationship to Steve Howe?
A. Currently?
Q. Yeah.
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Mobooka, did you do that kind of -- that same work as a
buyer for different companies?
A. So to be clear, I never worked for a company
call Mobooka. So that kind of -- now, I'm confused.
Convert2Media.
A. At Convert2Media I've never done sales of any
kind.
Q. You just stated you were the buyer?
A. Right.
Q. Okay. Did you ever act as a buyer on behalf of
any other companies while you were working for
Convert2Media?
A. Yes.
Q. Which companies?
A. My company, Forsa.
Q. And how did you find -- okay. So, when did you
create Forsa?
A. I don't recall. Maybe -- I don't recall. I
could guess. I could estimate if you'd like.
Q. No. That's okay. Did you create Forsa with
anybody else?
A. I didn't really understand the process. I just
used who I had learned to use which was a Wyoming I
believe they're called registry or registered agent. And
you just pay them a fee, and they make you a company and
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Q. Does he have any relation to Forsa?
A. No, but he -- let's see. No, he doesn't
have -- he never did any business at all with Forsa, no.
Q. Okay. So, Forsa you stated before you did the
same thing as you were doing at Convert2Media, correct?
A. No.
Q. You were the buyer; you were working with the
advertisers, and Forsa was getting paid when people
bought the shipping and handling?
A. Yes. Yes. Sorry.
Q. Okay. To be more exact. Because you weren't
doing the same exact thing. How were you finding these
advertisers?
A. I didn't have to. It wasn't my job.
Q. So, how did Forsa get these advertisers?
A. Forsa never had any -- Forsa was just -- it's
hard -- Forsa was just who got paid for the work.
Q. Okay. But you're working at Convert2Media;
you're a buyer working with the advertisers, right?
A. Right.
Q. How do these -- you're also working for Forsa
or for the benefit of Forsa?
A. Right.
Q. We can say that. Working with the advertisers.
How did the advertisers get to you?
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Convert2Media would get paid?
A. Yes.
Q. Okay. So, we're on the same page there. Now,
at the same time you were working for Convert2Media you
created Forsa LLC in Wyoming around that same time,
right?
A. Yes.
Q. Okay. Now, Forsa LLC -- now, for Forsa LLC you
would be a buyer as well?
A. Yes.
Q. Okay. But you're saying you were working with
advertising networks?
A. Right.
Q. So, these advertising networks were they
competitors to Convert2Media?
A. Yes.
Q. And you bought on these advertising networks'
behalf?
A. Right.
Q. To advertise?
A. Correct, yes.
Q. And the commissions you got would be paid to
you directly or to Forsa?
A. On -- Forsa.
Q. It would be paid to Forsa. Now, these
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advertisers that we're talking about that are paying the
commissions, how did you become aware of them?
A. I -- I honestly did not know -- I had no
awareness of them at all. I -- I would buy on behalf of
the network for whomever -- whichever advertiser pleased
them. I had no -- I had no contact with the advertisers.
I did not know the names of the advertisers. I just --
Q. But how did you buy from them then if you
didn't know their names or the contacts or anything like
that?
A. I was given links by the networks. That's what
the networks do. They serve as a cushion or a middleman
between media buyers and advertisers.
Q. So, you would just get links then from the
advertising networks?
A. Yes.
Q. So, Convert2Media would send you these links,
right? As a network, they would send you the links to
the advertisers?
A. If I were -- what are you asking?
Q. When you were working for Convert2Media.
A. When I was working for Convert2Media, I was
told by the sales staff, really just Steve Howe, which
products should be sold. I did not know who owned them.
I wasn't in contact with those people. I was just given
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what's called an affiliate link and told run this. And I
would then go and market an affiliate link that would
link to an advertiser's sales page hosted on
Convert2Media's network. That's how it works.
Q. And those that Steve Howe gave you
Convert2Media would be paid for any of the sales?
A. Right.
Q. Now, for any of these that Steve Howe gave you
was Convert2Media not paid?
A. For every sale that was made Convert2Media was
paid or unless there was a dispute by the advertiser in
which case Convert2Media would generally sue the
advertiser.
Q. Okay. Now, for any of these did you
divert -- did you take any of these links for your own
benefit?
A. That would not have been possible.
Q. Why not?
A. They're just links to products that
Convert2Media sells.
Q. Did you redirect any of the traffic through the
links back to your company Forsa?
A. I keep seeing this term in the documents, and I
don't know what it means. I know what redirect means,
but in the context it makes no sense at all. It has
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made the agreement. I was willing to pay him going
forward, but he was asking for a retroactive payment for
the money that I had already made. And I said that's not
going to happen.
Q. Did you have a written employment agreement
while working there at Convert2Media?
A. I -- I assume I did. I'm not really sure what
a written employment agreement is.
Q. Did you have any kind of contract with
Convert2Media, you know, saying you're going to be paid
this, you have to work this many days, you get vacation
this many days?
A. Yes, yes.
Q. Do you have a copy of it still?
A. No.
Q. Do you recall if that agreement addressed
working for different companies while you were working at
Convert2Media?
A. I do recall it. It did not.
Q. Did anybody else have side jobs while working
there?
A. Yes.
Q. Did they pay Convert2Media the 10 percent or
whatever it was?
A. They paid Steve Howe directly, yes.
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Q. But you didn't?
A. No, I did not.
Q. And did you know these people paid Steve Howe
directly from the time you were working there?
A. Yes.
Q. When you were terminated, at about that time,
did you go to Steve Howe's house?
A. We had the conversation -- our final
conversation took place at his house.
Q. And what did you talk about there?
A. We discussed that he knew that I was consulting
and making money. He discussed that I would need to pay
him 10 percent going forward, and he wanted on that day a
check for $14,000 which was 10 percent retroactively, and
I was not willing to do that. I was, however, willing to
pay going forward to retain my employment at
Convert2Media, but on principle I could not pay him
retroactively when we did not have an agreement. So, he
said never come back.
Q. Did --
A. I accepted that as my termination.
Q. Could you have been working for Convert2Media
while you were doing work for other entities?
A. Could I have been?
Q. Yes.
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Q. Did you manage internal redirect traffic?
A. No.
Q. So, are you saying this is -- did you create
Forsa around December of 2016?
A. I -- that -- I believe so. It sounds right
around the correct timing.
Q. Did you admit to taking any traffic from
Mobooka as stated here and receiving payment under your
own company?
A. No. That would not be possible.
Q. So, are you stating Michael Kerry is basically
lying under oath here?
A. Yes.
Q. Or are you lying under oath today?
A. Can you clarify your question?
Q. So, who's lying? Is it Michael Kerry or you?
A. Is your question --
Q. Someone -- there's two things under oath.
There's Michael Kerry and there's you today.
A. Right.
Q. Who's -- what's true?
A. Are you asking me if I'm giving false testimony
under oath, if I'm perjuring myself? Is that what you're
saying?
Q. Because there's a statement here that's
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everything. Everything would have been on there because,
you know, we all worked from our phones so everything was
on there.
Q. Including your LastPass passwords?
A. Everything. And if not, then -- then all the
other things would already be sort of logged into,
including LastPass. If you're asking if the password
would have been written in plain text somewhere on the
phone, no, but it would have already been logged into as
it was my phone so.
Q. Who is Keith Vogt?
A. I don't know a Keith.
Q. Vogt, V-o-g-t.
A. Not a name I've ever heard.
Q. Does Forsa do any work with AP Media?
A. Once again, no.
Q. Did Forsa ever have any other bank account than
the one Chase account?
A. No.
Q. Does Forsa's registered agent that you were
talking about before know anything about what Forsa does
or -- do they know anything about what Forsa does?
A. I would guess not. I don't recall ever having
to explain.
Q. They're just the registered agent?
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A. Yes.
Q. Okay. So, you don't work with them or anything
like that?
A. I don't even know who they are. It's an online
forum, and you pay with PayPal or something like that.
MR. GITTLE: Okay. I think that's it.
(Discussion off the record.)
(Deposition concluded at 12:34 p.m.)
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(786) 522-0522Exhibit “B”0000 AT&T > 5:56 PM 47 66% i )4
<@ @ ®
John
Thu, Apr 13, 6:47 PM
Man the worst thing is that |
know you don't need this stress
on top of everything else. I'm
sorry. We will make this right.
I'm not going to involve police
should everything be paid back
Tamiell
Oh, no doubt.
I've spent the last hour
changing passwords and on
phone calls. This is reediculous
| wish you didn't have to go
through this.
I'm not going to fuck with
anything.
ae © o©0000 AT&T > 5:56 PM 4 66% i+
<@ @ ®
John
It's hard not to. This was the
last thing you needed right
now.
| honestly thought we would
work together in some capacity
until | died.
Friday 1:28 PM
John i need URL / user / pass
for all the voluum accounts
asap
Ok but I'm locked out of my
LastPass.
Let me try and remember
them.
Then provide your LastPass
(pass)
ke
ae © @@0000 AT&T F 5:57 PM 4 66% +
<@ @ ®
John
Look in web history for URLe000 AT&T > 5:57 PM 47 66% Li )4
<@ @
John
Don't make this worse bro
If u want | can get law
enforcement involved John
No problem
Do you not understand this is
criminal John
©
I'm trying to give you easy way
out
But if you don't cooperate and
withhold (SMS code / urls /
desktop password) it will only
get worse
Whoa just got all this. Sorry I'm
at a family thing.
| didn't realize the voluums
were an emergency.
oe @ © ( iMessage Q@e000 AT&T > 5:57 PM 4 66% +
5:57 PM 4 66% i+
<@ @ ®
John
Your LastPass verification code
is 209478
| feel like my LastPass isn't
needed though. | was stupid
and saved a bunch of personal
stuff in there.
Bro | need it
I'm accessing voluum
Resend new code
Last pass code please.
Can | go in and remove my
personal stuff and move it to a
new account?
| literally have everything like
personal email accounts and
utilities and almost everything.
I'm accessing voluum. I'm not
going to pull a John
a ¢€ @ e00000 AT&T =F 5:58 PM 4 66% G4
<@ JH ©
John
| know. I'm giving you all of the
Voluum logins though.
It doesn't seem necessary.
You have given me 2 of 5
That Mobooka one hasn't been
paid for in over a year though.
Well how was it running?
Which one is active for
Mobooka and c2m
ae © O©0000 AT&T > 5:58 PM 4 67% C4
<@ @ ®
John
Not the ones you gave me
Monday 9:19 AM
- : srvasneo0 04020 9-100
ar nar
De
fot Over ignored ‘818 Amount FRecoved invoce Sent Payment Pay
217 Rotover ‘5200 ck Paid
ov ‘susa009 ‘Becabed voice aid-2e2207 Uns
a7 474400 ‘Received inci aid 2087017 Une
a7 s1z00200 ‘Received voi Pet 22017 Unk
ow sa92400 ecaivedinvlce Be 202017 Une
o7 $2,094.00 ‘Becatve invoice Paid 1282017 =U
a7 $2248.00 ‘Becetved invoice Paid 1182017 Un
7 s172800 Beceive invoice Pet u017 Une
ov s271200 Beceived invoice Pnitaz017 Une
2018 samz00 ‘Received inci Pad 12282016 Un
s2018 2.41000 ‘Received ince Pua 12212016 Une
2016 1.51800 ‘Received inci Paid 12142016 Und
2018 ‘$988.00 ‘Received invoice aid 120772016 Une
‘018 ‘100800 ‘Received invoice Baie 117292016 Unk
2016 2.97400 ‘Received invoice Pog t1016 = Un
32016 84000 ‘Received inci Pad t2R018 Un
20 ‘830.00 ‘Received ino Pad 10282016 Uns
$60,376.00 0-80.00 16. $68,014.00
| expect a bank check by noon
today at the Mobooka office
turned into Kym.
| have full click logs / bank
payment details. | have
contacted the Wyoming
registered agent. | have ip login
a ¢€ © ©@0000 AT&T = 5:58 PM 4 67% C4
5:59 PM 4 67% E14
<@ @ ®
John
OCOEE, FL 34761
Routing Number:
Swift Code: WFBIUS6S
Account Number:
Oh even better.
Okay cool. Thank you.
Today John
Ok. Today.
I'll wait for a pending wire
receipt
‘$60,376.00 0-50.00
Ed
Heme | Campeigns | SibAmiates | Tati | Reterrate | Accounting Contacts | Documents | History@0000 AT&T = 5:59 PM 4 67% G4
<@ @ ®
360,376.00 0-30.00 16 $08,014.00
Ed
Nome | Campaigns SubAmuates | Tat | Reterraie Accounting Contacts | Documents | History
ot Over grove ‘BE Amour Recaed invace ‘eee
a yar
ae ‘saszenn ected icice Pid -aniza17
oa ‘1490500 ‘Recta Bud 52007
a ‘saset00 ‘Boome imme id =a?
a preety ‘Becht inca Paid -2a2017
a suse ‘Beco id= aa017
a prery ‘Recover ike Pad -a2017
Gz saszz09 cctv nice Paid 20@037
am sameeo Recaed e Paid - 2292017
G2 mam ‘ecover inmice id= 282017
S114 400 -s000 9-srtasecco
eal dese Pewee
Thank you.
Send the wire receipt. You have
til noon.
Monday 10:59 AM
Still no wire receipt
Bank wires take 15 mins on the
phone@0000 AT&T F 5:59 PM 4 67% C4
John@0@000 AT&T = 5:59 PM 4 67% )4
John
Monday 2:01 PM
Yesterday 12:54 PM
a ¢ © Oo@0000 AT&T = 5:59 PM 4 67% G4
John
Yesterday 12:54 PM
Delivered
a € @ oExhibit “C”IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE
COUNTY, FLORIDA
MOBOOKA, LLC., a Florida limited liability CASE NO: 2017-CA-004043
company,
Plaintiff,
v.
JOHN HANCOCK, individually, FORSA LLC,
a Wyoming limited liability company, and
JPMORGAN CHASE BANK, N.A., an Ohio
banking corporation,
Defendants.
DEFENDANTS RESPONSE TO REQUEST FOR ADMISSIONS
1. Admit you worked for Mobooka during the period of January 2017 until April.
Response #1: Deny
2. Admit you formed Forsa, or directed Forsa to be created by your agent.
Response #2: Admit
3. Admit you worked as an Internal Redirect Manager during your time at Mobooka
Response #3: Deny
4. Admit that you went to the home of Steve Howe on or about April 16, 2017.
Response #4: Admit
5. Admit you admitted to Steve Howe that you redirected traffic from Mobooka to Forsa.
Response #5: Deny
6. Admit you agreed to pay Mobooka back for the traffic you wrongfully redirected.
Response #6: Deny7. Admit Mobooka did not authorize you to redirect traffic to other entities.
Response #7: Admit
8. Admit you had access to trade secret material while working at Mobooka.
Response #8: Deny
9 Admit you had access to Mobooka client lists while working there.
Response #9: Deny
10. Admit you refused to hand over passwords and security codes to Mobooka after the
your employment there.
Response #10: Deny
11. Admit you owed a duty of loyalty to Mobooka while working there to not take
actions which would harm or have an adverse reaction on Mobooka’s business.
Response #11: Deny
12. Admit you had actual knowledge of MOBOOKA’s advertising clients.
Response #12: Deny
13. Admit you were aware of the prospective redirect traffic generated by MOBOOKA
and the revenues associated with such redirect traffic.
Response #13: Deny
14. Admit you knew that you were interfering with MOBOOKA’s advertising client
relationships by intentionally redirecting internal network traffic generated by
MOBOOKA to a competitor network.Response #14: Deny
15. Admit you caused Mobooka’s competitor network to pay out the revenue
Corresponding to the network traffic to Forsa.
Response #15: Deny
16. Admit you received the notice attached as Exhibit “B,” to the Amended Complaint
in this case.
Response #16: Admit
17. Admit you visited the country of Aruba during your employment at Mobooka.
Response #17: Deny
18. Admit you had access to the Valuum performance marketing tracker platform.
Response #18: Deny
19. Admit you created and ran AP Media.
Response #19: Deny
Dated this 30th day of November, 2018
Respectfully Submitted
John Hancock
499 Hammock Dr.
Palm Harbor, FL 34683
(407) 785-8685
hancock,j. mail.com
By: John HancockExhibit “D”IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE
COUNTY, FLORIDA
MOBOOKA, LLC.., a Florida limited CASE NO: 2017-CA-004043
liability company,
Plaintiff,
v.
JOHN HANCOCK, individually; et al.,
Defendants.
DEFENDANT JOHN HANCOCK’S RESPONSE TO
PLAINTIFF MOBOOKA LLC’S FIRST SET OF INTERROGATORIES
INTERROGATORIES:
1. Identify yourself, and indicate the names, titles, addresses and telephone numbers of
each and every person preparing or assisting in the preparation of the responses to
these interrogatories.
Answer #1: John Hancock. (407) 785-8685. 499 Hammock Dr. Palm Harbor, FL
34683
2. Please identify all persons who are believed or known by you, your agents, or your
attorneys to have any knowledge concerning any of the issues in this lawsuit; and for
each provide their name, business and residence addresses, business and residence
telephone numbers, and specify the subject matter about which the witness has
knowledge.
Answer #2: | believe that Michael Kerry, Stephen Howe and possibly any
employees of Mobooka, LLC have knowledge of this lawsuit.
3. Describe with particularity your job duties and any positions held while you were
employed by Mobooka.
Answer #3: | was never employed by Mobooka.4. Identify all email addresses, both personal and work related, used during your tenure
at Mobooka.
Answer #4: | never worked at mobooka. Emails that | used during the timeframe specified
in this lawsuit are: hancockenator@gmail.com, hancock.j.g@gmail.com.
john@convert2media.com, adops@convert2media.com
5. Identify all bank accounts held during your time at Mobooka and until the current
date.
Answer #5: | never worked at mobooka. Bank accounts that | used during the timeframe
specified in this lawsuit are: Chase Checking Account ending in 9873, Chase
Savings Account, and a Chase Business Checking Account for Forsa, LLC.
6. Please describe with particularity the meeting you had with Mr. Steve Howe (“Mr.
Howe’) at Mr. Howe’s home on or about April 16, 2017 and all conversations with Mr.
Howe at that time.
Answer #6: Steve Howe confronted me after realizing | had been running traffic on
my own and not paying him a cut of my hard earned money. He told me | could
keep my job if | wrote him a check for around $14,000 in royalties for the money |
had made so far and then continue to pay him 10% of my earnings thereafter. |
declined this offer and he confiscated my company phone and told me my time
under his employ was terminated.
7. State all performance marketing trackers you had access to while employed at
Mobooka.
Answer #7: Volume performance tracker.
8. State with specificity all log in passwords you used to log into any desktop or laptop
computer you used while working for Plaintiff, and state all log in information including
passwords to any Mobooka email addresses or programs you had while employed
there.
Answer #8: | never worked at Mobooka. During the timeframe specified in this lawsuit, |
was working at Convert2Media, my computer password was “c2m”.
9. Please describe with particularity your purposes in creating Forsa.Answer #9: I created Forsa to anonymously run traffic on behalf of a network other
than the one at which | was employed.
10. Please state each item of damage that you claim, whether as an affirmative claim or
as a setoff, and include in your answer: the count or defense to which the item of
damages relates; the category into which each item of damages falls, i.e. general
damages, special or consequential damages, interest, and any other relevant
categories; the complete factual basis for each item of damages; and an explanation of
how you computed each item of damages, including any mathematical formula used.
Answer #10: No damages.
11. Please identify any and all correspondence or communication you had with any
individual(s) or any entity that may have knowledge concerning any of the issues in this
lawsuit.
Answer #11: | have only had conversation with Michael Kerry about his lawsuit in
which | asked him to end this frivolous lawsuit.
12. Please identify any and all lawsuits you have been a party to within the last five (5)
years.
Answer #12: No Lawsuits.
13. Please identify any document you intend to use at trial as evidence, impeachment,
rebuttal,or to refresh recollection.
Answer #13: None available at the moment.
14. Identify each person you intend to refer to at trial and/or call as a witness at trial to
offer testimony on your behalf, such person’s current address and telephone number,
and identify the subject matter and general substance of the expected testimony of
each.
l intend to call Stephen Howe and Michael Kerry as witnesses.
15. Have you ever taken a trip to Aruba while employed at Mobooka? If so, state the
dates of said trip.Answer #15: | have never been to Aruba.
16. Describe with particularity your affiliation with AP Media.
Answer #16: | have no affiliation with AP Media.
Respectfully Submitted
John Hancock
499 Hammock Dr.
Palm Harbor, FL 34683
(407) 785-8685
hancock.j.g@gmail.com
By: John HancockExhibit “E”= Pes
luiniktown
Other Unknown
Lila lel
FL.
Ea —€ |
Dlarrestes Wantes
Yj
BUSINESS: VICTIM
MOBOOKA LLC Tite 881684
[3510 § MAGUIRE R [Store l Fe]
CHARGES
Sima Ezvacteat [PARE
rcrarge Degree iy. PaICBAL (Ci Domestic violence
(Charge Desorption
RAND THEFT :GREE($100,000 OR
ci
WY
Page 1 of 2[Agencj Case Number
OCPD170FF001538
[Report Date! Time
04/17/2017 02:09 PM.
‘Onense Descrigtion
44-1 FRAUD ones THAN CR. CARD/CHECK S/THEFT)
[CAD incident Number
OCPD17CAD021445
Enteral Case Reterence NumDer
Tabasote 124 Thor AM t AM to 04/13/2017 03:00 PM
_
REPORTING OFFICER / SUPERVISOR APPROVAL
Reporting Omicer
[Sai Nanber —] Name
1053 l STRONG, AMANDA
Agproving Supenicor
ss ra
254 [CORPORAL [eDWaRDS, GLEN
Signature
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sigrstre
Page 2 of 2OCOEE POLICE DEPARTMENT
STATEMENT FORM [_] CONTINUATION | Nostir: Qron ececo 1526 |
PERSON MAKING STATEMENT IS: “ARRESTED? JUVENILE? :
[MFVICTIM §=§/-OWNER [ }WITNESS [ }SUSPECT [ }OTHERLO (L1YES [yAXo C1YBS [NO
NUM pammrameac Tae SE, | Dow AGE
sisohadtistsl Stes, w | | bss |
sai eve HMORLOCATED ORT [oeamenresronr_{ rETEED pa a C*d
—=— = =
EMPLOYER | PHONE ‘ADDRESS: cr ‘SuTE zp
on OTHER - wp eie = i . See .
Z A DO HEREBY VOLUNTARILY MAKE THE FOLLOWING STATEMENT
WITHOUT THREAT, CORLGION, OFFER OF BENEFIT OR FAVOR BY ANY PERSONS WHOMSOEVER.
TE am one oS “he mers Porkners of Moebake Lic Which
is en ASsuale Neboork, ean Vkncock 16 an employee.
ho Managed 000 rherne Tedvced WeSGe edhadk ganesh daly
Centensre. rear Sopetkee croead Dxcendae af Io 2 he Crede§ >
Vg mon Cotnpeny and Broceedd Yo ceswred vr inderag redepeh
ene do Daepebye vas les oon Corp. “tre Aw QQe
Wak toes ate Gaon Mobeka re gorahere erosnl $96. Shue
Nw exbe. x \ing “Mn And, Teereuas ran
wee \ne Soon carp. We as” a Semgens vmod \Ne AS Dress
Cherges aod us AK Nest bn Covrk,
SWORN TO AND SUBSCRIBED. ‘THE UNDERSIGNED AUTHORITY, I SWEAR/ AFFIRM THE ABOVE STATEMENT IS TRUE AND CORRECT. Under
penalties of perjury, I declare sit Vhaye read the foregoing [document] and
| THES. \ bu DAY OF, 204, that the facts stated iazit areftup
aT_14aS, HOURS.
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+ MIRANDA WARNING Wo’ ‘CHARGES ‘Way Testy
Pace_l_or\ . YES[ J NO YESH] NO[] ‘YES [ NO[]
Rev.05/27/2003Exhibit “F”@0000 AT&T = 5:51PM 4 63% Li )4
< Chats Jonathan Cole
last seen 1 hour ago
Hey buddy are you around? 9-55 pyy
Yea 3:33 pmw
don't mean to bug you however for
some reason your Mobooka global
redirect is going to us outside of FL to
arandom affiliate of ours.. | think you
may have someone splitting off traffic.
3:34 PM
Interesting. So out global redirect is
hitting a pub account on your side
3:34 PM
yeah two of them if you're outside FI
for us and anything international
35 PM
https://www.dropbox.com/s/w7b8jrd1
w9u8daf/Screenshot%202017-04-13
%2014.51.56.png?dl=0
Dropbox
Screenshot 2017-04-13
14.51.56.png . >
od
Shared with Dropbox
3:35 PM
Vv
Damn 3:35 pw
g O@0000 ATAT & 5:51PM 4 63% (4
< Chats Jonathan Cole
last seen 1 hour ago
an affiliate 'AP Media' and 'Forsa' on
our end.
What are payment details 3-33 py y
both chase bank in Florida
https://whois.domaintools.com/65.124
.195.194/ had a login from this ip.. will
send over payment details shortly
Forsa LLC
Chase
Account Number:
Routing Number:
Account number: jie
Routing Number: aa
I'll get to the bottom of it. Jeez man |
pray it is not what it looks like 3.44 pyy
That is our lO 3:45 puw
IP 3:45 pM.”
VY
WOW 23:45 Pn.
@ g@0000 AT&T = 5:51PM 4 63%) 4
Jonathan Cole
< Chats last seen 1 hour ago
yeah &9 sorry you have to deal with
that it's 100% someone there whoever
has access to that voluum
yea we have like 4/5 accounts on
Vollum 3:46 PM /
$213898 in revenue 2-47 py
JESUS 3-47 puw
3grs6 voluuM 2-5; py
3grs6 what is that 3-59 pyw
the account name? 2:59 py vw
the voluum for your global redirect
and the one the person is splitting off
traffic with
OK 3:52 puw
got it 252 puw
is there any more personal details
associated with the accounts?
4:09 Pr, Vv
g Q@0000 AT&T 5:51PM 4 63% Ci )4
< chats onatnan Cole ©
name? 4:09 puw
phone? 4:09 puw
email? 4:09 puw
god, this pisses me off. you pay
employees so much 4:10 PMY
what is the date range on this traffic
which was sent? 4:12 PM
was it all paid out ON? 4:72 py w
One sec ill get all the details 4-45 py,
TY 4:16 PMV
All except $7500 or so has been paid.
hold that 4:76 puw
Holding for now ill send it to you if
anything
if u feel comfortable 4.77 py y
when did it start 4.4762 \/
g Q@0000 AT&T = 5:51PM 4 64% C4
< Chats Jonathan Cole
last seen 1 hour ago
It started with ‘AP Media’ AfflD
213872.. Contact details:
https://www.dropbox.com/s/w57g4k6
zqkfghgu/Screenshot%202017-04-13
%2016.17.36.png?dl=0 .. Date Range
10/17-2:26.
Dropbox
Screenshot 2017-04-13
16.17.36.png >
Shared with Dropbox eS
4:19 PM
Then earlier this year ‘Ap Media’ aka
Andreas patino introduced ‘Forsa LLC’
torun.. Their address is the same
address that we both used for our
offers in WY when we started them.
4:19 PM
https://www.dropbox.com/s/6tsczasw
2e8w28c/Screenshot%202017-04-13
%2016.20.10.ong?dl=0
Dropbox
Screenshot 2017-04-13
16.20.10.png -s
oad
Shared with Dropbox@0000 AT&T & 5:51PM FT 64% 4
Jonathan Cole
< Chats last seen 1 hour ago
One of their home IP addresses is
50.89.131.45 if you can cross
reference your employee logins 4:29 pyy
And 184.89.148.35 4:20 py
https://wyobiz.wy.gov/business/Filing
Details.aspx?eFNum=0411150381050
092212340240400601302130091121
35149 - Is Forsa °1 PM
4:21 PM
Forsa is under Nathan Bennett
nbforsa@gqmail.com 4:21 PM
damn 4:2; puw
someone is putting in work 4:29 py yw
Forsa ran 2/6-this week 4.55 pyy
Who went on a trip to Aruba in
December? 4:22 PM
during Christmas 4.95 pyy
That is your leak 4.59 pry
interesting 4:22 p, \“
g Q©0000 AT&T = 5:52 PM 4 64% C4
< Chats Jonathan Cole
last seen 1 hour ago
i know that one 4:22 py
was there a log
Preview
Filing # 94717000 E-Filed 08/23/2019 06:46:34 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC., CIRCUIT CIVIL DIVISION a Florida limited liability company, _ Plaintiff, CASE NO.: 2017-CA-004043 v. JOHN HANCOCK, individually, FORSA LLC, a Wyoming limited liability company, Defendant. PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT III OF THE COMPLAINT AND MEMORANDUM OF LAW COMES NOW, the Plaintiff, MOBOOKA, LLC. (‘Plaintiff’), by and through the’ undersigned counsel, moves this court for an order pursuant to Fla. R. Civ. P. 1.510, granting Partial Summary Judgment against JOHN HANCOCK (“Defendant”), with respect to Count III of the Plaintiffs Second Amended Complaint and states as follows: PROCEDURAL BACKGROUND 1. On May 1*, 2017, the instant case was filed. 2. On June 6", 2018 and July 20", 2018, respectively, Plaintiff's Amended and Second Complaints were filed. 3. On October 25", 2018, this Court entered default against FORSA LLC (“FORSA”). 4. On February 7", 2019, this Court entered a final judgment in default against FORSA, as follows: “Plaintiff MOBOOKA LLC shall recover from FORSA LLC, the amount of Three Hundred Forty-Three Thousand Seven Hundred Dollars ($343,782.00), which sum shall bear interest rate of 6.33% per annum from the date of this Final Page 1 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comJudgment...Plaintiff is entitled to its reasonable attorney’s fees and taxable costs and the court retains jurisdiction to determine the reasonableness thereof.” 5. Defendant’s Answer to Plaintiff's Second Amended Complaint was filed on April 12", 2019; which consisted of a general denial of all counts, and no affirmative defenses. 6. Plaintiff now moves for Partial Summary Judgment against Defendant John Hancock, on Count III of its Second Amended Complaint — Civil Theft. FACTUAL BACKGROUND 7. Plaintiff is a marketing and advertising agency specializing in affiliate marketing, mobile and online advertising, and search engine marketing. 8. The commercial name of Plaintiff is Convert2Media. 9. Defendant was employed by Plaintiff as an Internal Redirect Manager, whose primary function was to manage redirect traffic for several advertising and marketing networks, including for Plaintiff. 10. On or about April 13, 2017, a competitor network, discovered suspicious traffic redirects from Plaintiff to the competitor from an unknown network affiliate, FORSA. 11. Upon further investigation, it was discovered that Defendant was redirecting traffic generated by Plaintiff to FORSA, which generated $114,594.00 in revenue for FORSA. 12. Furthermore, the revenue generated by Defendant from redirecting Plaintiff’s traffic to FORSA was deposited to FORSA and Defendant’s accounts =! and at CHASE BANK. Defendant is also the accountholder for the HE account at CHASE BANK where the redirect revenues were being paid to. 13. When Plaintiff confronted Defendant of the discrepancy regarding Plaintiff ‘s traffic being tedirected to FORSA, Defendant confessed to Plaintiff of his actions and promised to pay back Plaintiff the revenue generated by Defendant by redirecting Plaintiff ‘s traffic to FORSA. Page 2 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 * T: (786) 837-6787 F: (305) 718-0687 * www.epgdlaw.com14. To this date, Defendant has made no attempts to refund or return the sum of $114,594.00 to Plaintiff. 15. As a result of Defendant’s actions, Plaintiff has suffered damages. STATEMENT OF UNDISPUTED FACTS 16. Defendant has admitted that he was an employee of Convert2Media, and not Mobooka, on the dates of the incidents that give rise to this cause of action (Dec. 2016 - Apr. 2017). See Exhibit A - Deposition of John Gant Hancock, page 11, paragraphs 5-6: 5 Q. “And when did you work for Convert2Media?” 6A. “I believe it was March 2015 to April 2017.” 17. Defendant has admitted that he created FORSA, on or about December 2016, while he was an employee at Convert2Media - See Exhibit A at page 36, paragraphs 3-7; page 58, paragraphs 3-6: 3 Q “Now, at the same time you were working for Convert2Media you created Forsa LLC in Wyoming around that same time, right?” 7A. “Yes.” 3Q “[DJid you create Forsa around December of 2016? 5A. “I -- that -- | believe so. It sounds right around the correct timing.” 18. Defendant has admitted that the only other individual who appears as agent of FORSA, Mr. Nathan Bennett, was merely hired to file the incorporation documents of FORSA, and has no other involvement in the company other than as Registered Agent. See Exhibit A at pages 68, paragraphs 20-25; page 69, paragraphs 1-4: 20 Q. “Does Forsa's registered agent that you were talking about before know anything about what Forsa does or -- do they know anything about what Forsa are would guess not. | don't recall ever having to explain.” 25 Q. “They're just the registered agent?” 1A. “Yes.” 2 Q. Okay. So, you don't work with them or anything like that?” Page 3 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com4A. “I don't even know who they are. It's an online forum, and you pay with PayPal or something like that.” 19. Defendant has admitted that he in fact redirected traffic from Mobooka to other networks, with the intent of excluding Mobooka from the benefit of the business obtained by that traffic. See Exhibit B — iMessage Conversation between John Hancock — Steve Howe: “You're saying | went into Walmart and took money from the safe. A more accurate accusation would be that | stood outside and sent customers to [TJarget. | don’t even need to have this argument, | already agreed to make it right. 20. Defendant has admitted that by redirecting traffic outside of his Mobooka’s network, thereby denying Mobooka’s earning, he committed a crime. See Exhibit B: “Well, | definitely don’t feel good about what happened, regardless of which crime was committed”. 21. Defendant has admitted that he did not have independent access to the affiliate links he tedirected to Mobooka’s competitor’s, other than the access he obtained as an employee of Convert2Media. See Exhibit A at page 37, paragraphs 8-22; page 38, paragraphs 1-4: 8 Q. “But how did you buy from them then if you didn't know their names or the contacts or anything like that?” 11 A. “l was given links by the networks. That's what the networks do.” 22 A. “When | was working for Convert2Media, | was told by the sales staff, really just Steve Howe, which products should be sold. | did not know who owned them. | wasn't in contact with those people. | was just given what's called an affiliate link and told run this. And | would then go and market an affiliate link that would link to an advertiser's sales page hosted on Convert2Media's network. That's how it works.” 22. Defendant has admitted that, while he was a buyer for Covert2Media, he acted as a buyer on behalf of any other companies, mainly his Company, FORSA. See Exhibit A at page 31, paragraphs 10-15: 10 Q “Did you ever act as a buyer on behalf of any other companies while you were working for Convert2Media?” 13 A “Yes.” 14 Q. "Which companies?” 15 A. “My company, Forsa.” Page 4 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com23 Defendant has admitted that, as an employee of Convert2Media, he was a buyer who worked with advertisers. 24 Defendant also admitted that, while an employee of Convert2Media, he created FORSA while at the same time, he was working for FORSA, for the benefit of FORSA, working as a buyer. See Exhibit A at page 34, paragraphs 18-23: 18 Q. “Okay, but you're working at Convert2Media; you're a buyer working with the advertisers, right? 20 A. “Right.” 21 Q. “How do these -- you're also working for Forsa or for the benefit of Forsa? 23 A. Right. 25 Defendant has admitted that the networks he worked with, on behalf of his company FORSA, were competitors of Convert2Media. Defendant also admitted that, as buyer for FORSA, he purchased media on these advertising networks' behalf, to advertise; and as a result, the commissions received from these activities, were paid to FORSA. See Exhibit A at page 36, paragraphs 3-24: 3 Q. “Okay. So, we're on the same page there. Now, at the same time you were working for Convert2Media you created Forsa LLC in Wyoming around that same time, right?” 7A. “Yes.” 8 Q. “Okay. Now, Forsa LLC -- now, for Forsa LLC you would be a buyer as well?” 10 A. “Yes.” 11 Q. “Okay. But you're saying you were working with advertising networks?” 13 A. “Right.” 14 Q. “So, these advertising networks were they competitors to Convert2Media?” 16 A. “Yes.” 17 Q. “And you bought on these advertising networks’ behalf?” 19 A. “Right.” 20 Q. “To advertise?” 21 A. “Correct, yes.” 22 Q. “And the commissions you got would be paid to you directly or to Forsa?” 24 A. “On -- Forsa.” 26 Defendant has admitted that his other fellow employees at Convert2Media worked “side jobs” while working at Convert2Media, and these fellow employees paid commission percentages Page 5 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comto Convert2Media, via Mr. Steve Howe, on said “side jobs”. Defendant further admitted that he in fact did not pay Mr. Howe or Convert 2Media any commission percentages from his “side job” at FORSA. See Exhibit A at page 52, paragraphs 20-25; page 53, paragraphs 1-5: 20 Q. “Did anybody else have side jobs while working there?” 22 A. “Yes.” 23 Q. “Did they pay Convert2Media the 10 percent or whatever it was?” 25 A. “They paid Steve Howe directly, yes.” 1 Q. “But you didn't?” 2A. “No, | did not.” 3 Q. “And did you know these people paid Steve Howe directly from the time you were working there?” 5A. “Yes.” 27 Defendant has admitted that Mobooka did not authorize him to redirect traffic to other entities. See Exhibit C — Defendant’s Response to Plaintiff's Requests for Admission #7. RFA #7 — “Admit Mobooka did not authorize you to redirect traffic to other entities.” Response #7: “Admit” 28 Defendant has admitted that he created FORSA to anonymously run traffic on behalf of a network other than the one at which he was employed. See Exhibit D — Defendant’s Response to Plaintiff’s Interrogatories #9: “| created Forsa to anonymously run traffic on behalf of a network other than the one at which | was employed.” 29 It is irrefutable that the proceeds of generated from the redirecting of traffic caused by Defendant, were deposited in the Chase Bank account owned by FORSA. See Exhibit B - Chart of Payments within iMessage Conversation. 30 It is irrefutable that Defendant, as an employee who managed Convert2Media’s internal redirect traffic, created his own company and proceeded to redirect Mobooka’s internal redirect traffic to a competitor under his own corporation. It is also irrefutable that Defendant verbally Page 6 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comadmitted to stealing this traffic and receiving payment under his own LLC. See Exhibit E - Ocoee Police Report. 31 Itis irrefutable that Defendant, on April 13, 2019, visited the residence of C2M’s partner, Mr. Steve Howe, and admitted his wrongdoing. See Exhibit E - Ocoee Police Report; Exhibit F — WhatsApp Messages (Steve Howe — Johnathan Cole). MEMORANDUM OF LAW L Motion for Summary Judgment 32 Summary judgment is proper where “the pleadings, depositions, answers to interrogatories, and admissions on file together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” Fla. R. Civ. P. 1.510 (c); Emile v. First Nat'l Bank of Miami, 126 So. 2d 305,306 (Fla. 3d DCA 1961). 33 Once the moving party meets this burden in demonstrating that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law, the party opposing entry of summary judgment must prove the existence of genuine triable issues. First North American Nat. Bank v. Hummel, 825 So.2d 502, 503 (Fla. 2d DCA 2002). 34 The opposing party must demonstrate the existence of genuine issues of material fact by pointing to countervailing facts or justifiable inferences to be drawn from those facts; a mere denial of the allegations of the complaint is insufficient to show the non-existence of a material issue. Dozier & Gay Paint Co., Inc. v. Dilley, 518 So. 2d 946, 948 (Fla. 1st DCA 1988); 35 Mere existence of a dispute as to matters not material to the action will not preclude entry of summary judgment. Armstrong v. Southern Bell Tel. & Tel. Co., 366 So. 2d 88, 90 (Fla. Ist DCA 1987). Page 7 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com36 For purposes of summary judgment, a “material fact” is a fact that is essential to the resolution of legal questions raised in the case. Florida Dep't. Of Envtl. Reg. v. C.P. Developers, Inc., 512 So. 2d 258, 261 (Fla. 1st DCA 1987). 37 “Although it is true that, generally, fact issues relating to intent do not lend themselves to summary judgment, summary judgment is not precluded simply because the action involves an issue of intent.” Fleming v. Peoples First Fin. Sav. & Loan Ass'n, 667 So. 2d 273, 274 (Fla. Ist DCA 1995) I. Civil Theft Under Fla. Stat. §772.11 38 Fla. Stat. §772.11 provides as follows: “Any person who proves by clear and convincing evidence that he or she has been injured in any fashion by reason of any violation of ss. 812.012- 812.037 or s. 825.103(1) has a cause of action for threefold the actual damages sustained and, in any such action, is entitled to minimum damages in the amount of $200, and reasonable attorney's fees and court costs in the trial and appellate courts.” 39 Florida Statutes, § 812.014 sets forth theft as follows: “(1) A person commits theft if he or she knowingly obtains or uses, or endeavors to obtain or to use, the property of another with intent to, either temporarily or permanently: (a) Deprive the other person of a right to the property or a benefit from the property. (b) Appropriate the property to his or her own use or to the use of any person not entitled to the use of the property.” 40 To establish a claim for civil theft, a party must prove that a conversion has taken place and that the accused party has acted with criminal intent. Holland v. McCullen, 764 So.2d 810 (Fla. 2d DCA 2000). Page 8 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com41 In order to properly allege the element of criminal intent with respect to the crime of theft, it need only be shown that the perpetrator in question had the intent to either temporarily or permanently deprive the victim of property. Daniels v. State, 570 So.2d 319 (Fla. 2d DCA 1990). 42 Intent, being a state of mind, is often not subject to direct proof and can only be inferred from circumstances.” Segal v. State, 98 So. 3d 739, 743 (Fla. 4th DCA 2012). 43 The standard for clear and convincing evidence requires that the evidence must be of such weight that it produces in the mind of the trier of fact a firm belief or conviction, without hesitancy, as to the truth of the allegations sought to be established. LEGAL STANDARD AS APPLIED TO UNDISPUTED FACTS 44 There is no factual dispute that Defendant had no right or title of ownership to the affiliate links he used to redirect marketing traffic away from Plaintiff. 45 There is no factual dispute that Defendant had no authorization to use the affiliate links provided by Plaintiff in any way, other than at the direction and for the benefit of Plaintiff. 46 There is no factual dispute that Defendant knowingly redirected the marketing traffic to which Plaintiff was entitled to, to other sources mainly Plaintiff's competitors, with the intent of generating the income attributable from said traffic for himself, and thereby permanently depriving Plaintiff of all the earnings associated from this traffic. 47 There is no factual dispute that Defendant engaged in said activity, with the intent of benefiting himself personally. 48 There is no factual dispute that Defendant went to extreme lengths in furtherance of his unlawful scheme; so much so, that he set up a shell corporation out of state, and proceeded to create banking accounts for said corporation, for the sole purpose of depositing the earnings Page 9 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comwrongfully received by virtue of siphoning Plaintiff's traffic, in an attempt to conceal his activity, in order to escape detection from Plaintiff. 49 There is no factual dispute that Defendant successfully carried out his scheme, depositing hundreds of thousands of dollars belonging to Plaintiff, in the banking accounts he created exclusively to carry out this scheme. 50 There is no factual dispute that Defendant admitted his wrongdoing to Plaintiff on several occasions, and agreed to make things right with Plaintiff. 51 Furthermore, Defendant has not provided any evidence supporting his denial of Plaintiff's allegations. 52 Thus, to the extent this Court enters a summary judgment on Plaintiff's Count III for Civil Theft, Plaintiff is entitled to the reimbursement of the attorney's fees and costs expended in prosecuting the above-styled Action. 53 Therefore, this Court should grant this Motion for Partial Summary Judgment as to Count III for Civil Theft Pursuant to Florida Statute sec. 772.11. CONCLUSION 54 Accordingly, there is no issue as to any material fact with respect to Count III of PLAINTIFF’S Second Amended Complaint for Civil Theft and PLAINTIFF is entitled to a judgment as a matter of law. 55 In light of Plaintiff's well-pled allegations and this instant Motion for Partial Final Summary Judgment, the burden has shifted onto Defendant to produce evidence in order to defeat said Motion. Page 10 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.com56 The summary judgment evidence in this case conclusively demonstrates that there are no genuine issues of material fact in this case, and Plaintiff is entitled to a judgment against Thorn as a matter of law. 57 There are no genuine issues of material fact that Defendant knowingly and intentionally committed civil theft under Florida law. Defendant’s intent is conclusive, demonstrated by his elaborate scheme to hide his actions, along with his own statements that he took funds from Plaintiff. WHEREFORE Plaintiff respectfully requests this honorable Court to grant this Motion for Partial Summary Judgment as to Count III (Civil Theft) of the Complaint, and any further relief the Court deems appropriate. EPGD ATTorRNEYS AT LAW, P.A. ATTORNEYS FOR PLAINTIFF 777 SW 37" Ave., Ste. 510 Miami, Florida 33135 Tel: (786) 837-6787 Fax: (305) 718-0687 sam@epgdlaw.com By: /s/ Samuel J Gittle Samuel J. Gittle, Esq. Florida Bar No.: 99778 CERTIFICATE OF SERVICE Thereby certify that a true and correct copy of the foregoing was furnished on this 23rd day’ of August, 2019 via Electronic Service and US Mail to John Hancock and FORSA LLC at hancock.j.g@gmail.com, 5305 Lisa Ave Lakeland, FL 33813 By: /s/ Samuel J. Gittle Samuel J. Gittle, Esq. Florida Bar No.: 099778 Page 11 of 11 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37" Avenue, Ste. 510, Miami, Florida 33135 + T: (786) 837-6787 F: (305) 718-0687 + www.epgdlaw.comExhibit “A”oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 A. Before Branded Response, I was in consulting, marketing consulting, in the affiliate marketing industry as well as a campaign manager at a company called Convert2Media which was an affiliate marketing network. Q. And when did you work for Convert2Media? A. I believe it was March 2015 to April 2017. Q. And Convert2Media is related to -- how is that related to Mobooka in your words? A. I -- as far as I know, they share an owner. Q. And what does your spouse do? A. How is that relevant? Q. The standard here is -- the legal standpoint is anything that may lead to admissible evidence. I mean if you had an attorney here -- A. I've been married since November 2017. Q. Okay. A. So, how is it relevant? Q. I just wanted to know what your wife does. Do you know what your wife does? A. She's in marketing. Q. Affiliate marketing? A. No. Q. What's your relationship to Steve Howe? A. Currently? Q. Yeah. Page 11 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 Mobooka, did you do that kind of -- that same work as a buyer for different companies? A. So to be clear, I never worked for a company call Mobooka. So that kind of -- now, I'm confused. Convert2Media. A. At Convert2Media I've never done sales of any kind. Q. You just stated you were the buyer? A. Right. Q. Okay. Did you ever act as a buyer on behalf of any other companies while you were working for Convert2Media? A. Yes. Q. Which companies? A. My company, Forsa. Q. And how did you find -- okay. So, when did you create Forsa? A. I don't recall. Maybe -- I don't recall. I could guess. I could estimate if you'd like. Q. No. That's okay. Did you create Forsa with anybody else? A. I didn't really understand the process. I just used who I had learned to use which was a Wyoming I believe they're called registry or registered agent. And you just pay them a fee, and they make you a company and Page 31 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 Q. Does he have any relation to Forsa? A. No, but he -- let's see. No, he doesn't have -- he never did any business at all with Forsa, no. Q. Okay. So, Forsa you stated before you did the same thing as you were doing at Convert2Media, correct? A. No. Q. You were the buyer; you were working with the advertisers, and Forsa was getting paid when people bought the shipping and handling? A. Yes. Yes. Sorry. Q. Okay. To be more exact. Because you weren't doing the same exact thing. How were you finding these advertisers? A. I didn't have to. It wasn't my job. Q. So, how did Forsa get these advertisers? A. Forsa never had any -- Forsa was just -- it's hard -- Forsa was just who got paid for the work. Q. Okay. But you're working at Convert2Media; you're a buyer working with the advertisers, right? A. Right. Q. How do these -- you're also working for Forsa or for the benefit of Forsa? A. Right. Q. We can say that. Working with the advertisers. How did the advertisers get to you? Page 34 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 Convert2Media would get paid? A. Yes. Q. Okay. So, we're on the same page there. Now, at the same time you were working for Convert2Media you created Forsa LLC in Wyoming around that same time, right? A. Yes. Q. Okay. Now, Forsa LLC -- now, for Forsa LLC you would be a buyer as well? A. Yes. Q. Okay. But you're saying you were working with advertising networks? A. Right. Q. So, these advertising networks were they competitors to Convert2Media? A. Yes. Q. And you bought on these advertising networks' behalf? A. Right. Q. To advertise? A. Correct, yes. Q. And the commissions you got would be paid to you directly or to Forsa? A. On -- Forsa. Q. It would be paid to Forsa. Now, these Page 36 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 advertisers that we're talking about that are paying the commissions, how did you become aware of them? A. I -- I honestly did not know -- I had no awareness of them at all. I -- I would buy on behalf of the network for whomever -- whichever advertiser pleased them. I had no -- I had no contact with the advertisers. I did not know the names of the advertisers. I just -- Q. But how did you buy from them then if you didn't know their names or the contacts or anything like that? A. I was given links by the networks. That's what the networks do. They serve as a cushion or a middleman between media buyers and advertisers. Q. So, you would just get links then from the advertising networks? A. Yes. Q. So, Convert2Media would send you these links, right? As a network, they would send you the links to the advertisers? A. If I were -- what are you asking? Q. When you were working for Convert2Media. A. When I was working for Convert2Media, I was told by the sales staff, really just Steve Howe, which products should be sold. I did not know who owned them. I wasn't in contact with those people. I was just given Page 37 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 what's called an affiliate link and told run this. And I would then go and market an affiliate link that would link to an advertiser's sales page hosted on Convert2Media's network. That's how it works. Q. And those that Steve Howe gave you Convert2Media would be paid for any of the sales? A. Right. Q. Now, for any of these that Steve Howe gave you was Convert2Media not paid? A. For every sale that was made Convert2Media was paid or unless there was a dispute by the advertiser in which case Convert2Media would generally sue the advertiser. Q. Okay. Now, for any of these did you divert -- did you take any of these links for your own benefit? A. That would not have been possible. Q. Why not? A. They're just links to products that Convert2Media sells. Q. Did you redirect any of the traffic through the links back to your company Forsa? A. I keep seeing this term in the documents, and I don't know what it means. I know what redirect means, but in the context it makes no sense at all. It has Page 38 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 made the agreement. I was willing to pay him going forward, but he was asking for a retroactive payment for the money that I had already made. And I said that's not going to happen. Q. Did you have a written employment agreement while working there at Convert2Media? A. I -- I assume I did. I'm not really sure what a written employment agreement is. Q. Did you have any kind of contract with Convert2Media, you know, saying you're going to be paid this, you have to work this many days, you get vacation this many days? A. Yes, yes. Q. Do you have a copy of it still? A. No. Q. Do you recall if that agreement addressed working for different companies while you were working at Convert2Media? A. I do recall it. It did not. Q. Did anybody else have side jobs while working there? A. Yes. Q. Did they pay Convert2Media the 10 percent or whatever it was? A. They paid Steve Howe directly, yes. Page 52 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 Q. But you didn't? A. No, I did not. Q. And did you know these people paid Steve Howe directly from the time you were working there? A. Yes. Q. When you were terminated, at about that time, did you go to Steve Howe's house? A. We had the conversation -- our final conversation took place at his house. Q. And what did you talk about there? A. We discussed that he knew that I was consulting and making money. He discussed that I would need to pay him 10 percent going forward, and he wanted on that day a check for $14,000 which was 10 percent retroactively, and I was not willing to do that. I was, however, willing to pay going forward to retain my employment at Convert2Media, but on principle I could not pay him retroactively when we did not have an agreement. So, he said never come back. Q. Did -- A. I accepted that as my termination. Q. Could you have been working for Convert2Media while you were doing work for other entities? A. Could I have been? Q. Yes. Page 53 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 Q. Did you manage internal redirect traffic? A. No. Q. So, are you saying this is -- did you create Forsa around December of 2016? A. I -- that -- I believe so. It sounds right around the correct timing. Q. Did you admit to taking any traffic from Mobooka as stated here and receiving payment under your own company? A. No. That would not be possible. Q. So, are you stating Michael Kerry is basically lying under oath here? A. Yes. Q. Or are you lying under oath today? A. Can you clarify your question? Q. So, who's lying? Is it Michael Kerry or you? A. Is your question -- Q. Someone -- there's two things under oath. There's Michael Kerry and there's you today. A. Right. Q. Who's -- what's true? A. Are you asking me if I'm giving false testimony under oath, if I'm perjuring myself? Is that what you're saying? Q. Because there's a statement here that's Page 58 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 everything. Everything would have been on there because, you know, we all worked from our phones so everything was on there. Q. Including your LastPass passwords? A. Everything. And if not, then -- then all the other things would already be sort of logged into, including LastPass. If you're asking if the password would have been written in plain text somewhere on the phone, no, but it would have already been logged into as it was my phone so. Q. Who is Keith Vogt? A. I don't know a Keith. Q. Vogt, V-o-g-t. A. Not a name I've ever heard. Q. Does Forsa do any work with AP Media? A. Once again, no. Q. Did Forsa ever have any other bank account than the one Chase account? A. No. Q. Does Forsa's registered agent that you were talking about before know anything about what Forsa does or -- do they know anything about what Forsa does? A. I would guess not. I don't recall ever having to explain. Q. They're just the registered agent? Page 68 info@dlecourtreporters.com (786) 522-0522oyoaouw 8 Wn KB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 John Hancock 10/22/2018 A. Yes. Q. Okay. So, you don't work with them or anything like that? A. I don't even know who they are. It's an online forum, and you pay with PayPal or something like that. MR. GITTLE: Okay. I think that's it. (Discussion off the record.) (Deposition concluded at 12:34 p.m.) Page 69 info@dlecourtreporters.com (786) 522-0522Exhibit “B”0000 AT&T > 5:56 PM 47 66% i )4 <@ @ ® John Thu, Apr 13, 6:47 PM Man the worst thing is that | know you don't need this stress on top of everything else. I'm sorry. We will make this right. I'm not going to involve police should everything be paid back Tamiell Oh, no doubt. I've spent the last hour changing passwords and on phone calls. This is reediculous | wish you didn't have to go through this. I'm not going to fuck with anything. ae © o©0000 AT&T > 5:56 PM 4 66% i+ <@ @ ® John It's hard not to. This was the last thing you needed right now. | honestly thought we would work together in some capacity until | died. Friday 1:28 PM John i need URL / user / pass for all the voluum accounts asap Ok but I'm locked out of my LastPass. Let me try and remember them. Then provide your LastPass (pass) ke ae © @@0000 AT&T F 5:57 PM 4 66% + <@ @ ® John Look in web history for URLe000 AT&T > 5:57 PM 47 66% Li )4 <@ @ John Don't make this worse bro If u want | can get law enforcement involved John No problem Do you not understand this is criminal John © I'm trying to give you easy way out But if you don't cooperate and withhold (SMS code / urls / desktop password) it will only get worse Whoa just got all this. Sorry I'm at a family thing. | didn't realize the voluums were an emergency. oe @ © ( iMessage Q@e000 AT&T > 5:57 PM 4 66% + 5:57 PM 4 66% i+ <@ @ ® John Your LastPass verification code is 209478 | feel like my LastPass isn't needed though. | was stupid and saved a bunch of personal stuff in there. Bro | need it I'm accessing voluum Resend new code Last pass code please. Can | go in and remove my personal stuff and move it to a new account? | literally have everything like personal email accounts and utilities and almost everything. I'm accessing voluum. I'm not going to pull a John a ¢€ @ e00000 AT&T =F 5:58 PM 4 66% G4 <@ JH © John | know. I'm giving you all of the Voluum logins though. It doesn't seem necessary. You have given me 2 of 5 That Mobooka one hasn't been paid for in over a year though. Well how was it running? Which one is active for Mobooka and c2m ae © O©0000 AT&T > 5:58 PM 4 67% C4 <@ @ ® John Not the ones you gave me Monday 9:19 AM - : srvasneo0 04020 9-100 ar nar De fot Over ignored ‘818 Amount FRecoved invoce Sent Payment Pay 217 Rotover ‘5200 ck Paid ov ‘susa009 ‘Becabed voice aid-2e2207 Uns a7 474400 ‘Received inci aid 2087017 Une a7 s1z00200 ‘Received voi Pet 22017 Unk ow sa92400 ecaivedinvlce Be 202017 Une o7 $2,094.00 ‘Becatve invoice Paid 1282017 =U a7 $2248.00 ‘Becetved invoice Paid 1182017 Un 7 s172800 Beceive invoice Pet u017 Une ov s271200 Beceived invoice Pnitaz017 Une 2018 samz00 ‘Received inci Pad 12282016 Un s2018 2.41000 ‘Received ince Pua 12212016 Une 2016 1.51800 ‘Received inci Paid 12142016 Und 2018 ‘$988.00 ‘Received invoice aid 120772016 Une ‘018 ‘100800 ‘Received invoice Baie 117292016 Unk 2016 2.97400 ‘Received invoice Pog t1016 = Un 32016 84000 ‘Received inci Pad t2R018 Un 20 ‘830.00 ‘Received ino Pad 10282016 Uns $60,376.00 0-80.00 16. $68,014.00 | expect a bank check by noon today at the Mobooka office turned into Kym. | have full click logs / bank payment details. | have contacted the Wyoming registered agent. | have ip login a ¢€ © ©@0000 AT&T = 5:58 PM 4 67% C4 5:59 PM 4 67% E14 <@ @ ® John OCOEE, FL 34761 Routing Number: Swift Code: WFBIUS6S Account Number: Oh even better. Okay cool. Thank you. Today John Ok. Today. I'll wait for a pending wire receipt ‘$60,376.00 0-50.00 Ed Heme | Campeigns | SibAmiates | Tati | Reterrate | Accounting Contacts | Documents | History@0000 AT&T = 5:59 PM 4 67% G4 <@ @ ® 360,376.00 0-30.00 16 $08,014.00 Ed Nome | Campaigns SubAmuates | Tat | Reterraie Accounting Contacts | Documents | History ot Over grove ‘BE Amour Recaed invace ‘eee a yar ae ‘saszenn ected icice Pid -aniza17 oa ‘1490500 ‘Recta Bud 52007 a ‘saset00 ‘Boome imme id =a? a preety ‘Becht inca Paid -2a2017 a suse ‘Beco id= aa017 a prery ‘Recover ike Pad -a2017 Gz saszz09 cctv nice Paid 20@037 am sameeo Recaed e Paid - 2292017 G2 mam ‘ecover inmice id= 282017 S114 400 -s000 9-srtasecco eal dese Pewee Thank you. Send the wire receipt. You have til noon. Monday 10:59 AM Still no wire receipt Bank wires take 15 mins on the phone@0000 AT&T F 5:59 PM 4 67% C4 John@0@000 AT&T = 5:59 PM 4 67% )4 John Monday 2:01 PM Yesterday 12:54 PM a ¢ © Oo@0000 AT&T = 5:59 PM 4 67% G4 John Yesterday 12:54 PM Delivered a € @ oExhibit “C”IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC., a Florida limited liability CASE NO: 2017-CA-004043 company, Plaintiff, v. JOHN HANCOCK, individually, FORSA LLC, a Wyoming limited liability company, and JPMORGAN CHASE BANK, N.A., an Ohio banking corporation, Defendants. DEFENDANTS RESPONSE TO REQUEST FOR ADMISSIONS 1. Admit you worked for Mobooka during the period of January 2017 until April. Response #1: Deny 2. Admit you formed Forsa, or directed Forsa to be created by your agent. Response #2: Admit 3. Admit you worked as an Internal Redirect Manager during your time at Mobooka Response #3: Deny 4. Admit that you went to the home of Steve Howe on or about April 16, 2017. Response #4: Admit 5. Admit you admitted to Steve Howe that you redirected traffic from Mobooka to Forsa. Response #5: Deny 6. Admit you agreed to pay Mobooka back for the traffic you wrongfully redirected. Response #6: Deny7. Admit Mobooka did not authorize you to redirect traffic to other entities. Response #7: Admit 8. Admit you had access to trade secret material while working at Mobooka. Response #8: Deny 9 Admit you had access to Mobooka client lists while working there. Response #9: Deny 10. Admit you refused to hand over passwords and security codes to Mobooka after the your employment there. Response #10: Deny 11. Admit you owed a duty of loyalty to Mobooka while working there to not take actions which would harm or have an adverse reaction on Mobooka’s business. Response #11: Deny 12. Admit you had actual knowledge of MOBOOKA’s advertising clients. Response #12: Deny 13. Admit you were aware of the prospective redirect traffic generated by MOBOOKA and the revenues associated with such redirect traffic. Response #13: Deny 14. Admit you knew that you were interfering with MOBOOKA’s advertising client relationships by intentionally redirecting internal network traffic generated by MOBOOKA to a competitor network.Response #14: Deny 15. Admit you caused Mobooka’s competitor network to pay out the revenue Corresponding to the network traffic to Forsa. Response #15: Deny 16. Admit you received the notice attached as Exhibit “B,” to the Amended Complaint in this case. Response #16: Admit 17. Admit you visited the country of Aruba during your employment at Mobooka. Response #17: Deny 18. Admit you had access to the Valuum performance marketing tracker platform. Response #18: Deny 19. Admit you created and ran AP Media. Response #19: Deny Dated this 30th day of November, 2018 Respectfully Submitted John Hancock 499 Hammock Dr. Palm Harbor, FL 34683 (407) 785-8685 hancock,j. mail.com By: John HancockExhibit “D”IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC.., a Florida limited CASE NO: 2017-CA-004043 liability company, Plaintiff, v. JOHN HANCOCK, individually; et al., Defendants. DEFENDANT JOHN HANCOCK’S RESPONSE TO PLAINTIFF MOBOOKA LLC’S FIRST SET OF INTERROGATORIES INTERROGATORIES: 1. Identify yourself, and indicate the names, titles, addresses and telephone numbers of each and every person preparing or assisting in the preparation of the responses to these interrogatories. Answer #1: John Hancock. (407) 785-8685. 499 Hammock Dr. Palm Harbor, FL 34683 2. Please identify all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and for each provide their name, business and residence addresses, business and residence telephone numbers, and specify the subject matter about which the witness has knowledge. Answer #2: | believe that Michael Kerry, Stephen Howe and possibly any employees of Mobooka, LLC have knowledge of this lawsuit. 3. Describe with particularity your job duties and any positions held while you were employed by Mobooka. Answer #3: | was never employed by Mobooka.4. Identify all email addresses, both personal and work related, used during your tenure at Mobooka. Answer #4: | never worked at mobooka. Emails that | used during the timeframe specified in this lawsuit are: hancockenator@gmail.com, hancock.j.g@gmail.com. john@convert2media.com, adops@convert2media.com 5. Identify all bank accounts held during your time at Mobooka and until the current date. Answer #5: | never worked at mobooka. Bank accounts that | used during the timeframe specified in this lawsuit are: Chase Checking Account ending in 9873, Chase Savings Account, and a Chase Business Checking Account for Forsa, LLC. 6. Please describe with particularity the meeting you had with Mr. Steve Howe (“Mr. Howe’) at Mr. Howe’s home on or about April 16, 2017 and all conversations with Mr. Howe at that time. Answer #6: Steve Howe confronted me after realizing | had been running traffic on my own and not paying him a cut of my hard earned money. He told me | could keep my job if | wrote him a check for around $14,000 in royalties for the money | had made so far and then continue to pay him 10% of my earnings thereafter. | declined this offer and he confiscated my company phone and told me my time under his employ was terminated. 7. State all performance marketing trackers you had access to while employed at Mobooka. Answer #7: Volume performance tracker. 8. State with specificity all log in passwords you used to log into any desktop or laptop computer you used while working for Plaintiff, and state all log in information including passwords to any Mobooka email addresses or programs you had while employed there. Answer #8: | never worked at Mobooka. During the timeframe specified in this lawsuit, | was working at Convert2Media, my computer password was “c2m”. 9. Please describe with particularity your purposes in creating Forsa.Answer #9: I created Forsa to anonymously run traffic on behalf of a network other than the one at which | was employed. 10. Please state each item of damage that you claim, whether as an affirmative claim or as a setoff, and include in your answer: the count or defense to which the item of damages relates; the category into which each item of damages falls, i.e. general damages, special or consequential damages, interest, and any other relevant categories; the complete factual basis for each item of damages; and an explanation of how you computed each item of damages, including any mathematical formula used. Answer #10: No damages. 11. Please identify any and all correspondence or communication you had with any individual(s) or any entity that may have knowledge concerning any of the issues in this lawsuit. Answer #11: | have only had conversation with Michael Kerry about his lawsuit in which | asked him to end this frivolous lawsuit. 12. Please identify any and all lawsuits you have been a party to within the last five (5) years. Answer #12: No Lawsuits. 13. Please identify any document you intend to use at trial as evidence, impeachment, rebuttal,or to refresh recollection. Answer #13: None available at the moment. 14. Identify each person you intend to refer to at trial and/or call as a witness at trial to offer testimony on your behalf, such person’s current address and telephone number, and identify the subject matter and general substance of the expected testimony of each. l intend to call Stephen Howe and Michael Kerry as witnesses. 15. Have you ever taken a trip to Aruba while employed at Mobooka? If so, state the dates of said trip.Answer #15: | have never been to Aruba. 16. Describe with particularity your affiliation with AP Media. Answer #16: | have no affiliation with AP Media. Respectfully Submitted John Hancock 499 Hammock Dr. Palm Harbor, FL 34683 (407) 785-8685 hancock.j.g@gmail.com By: John HancockExhibit “E”= Pes luiniktown Other Unknown Lila lel FL. Ea —€ | Dlarrestes Wantes Yj BUSINESS: VICTIM MOBOOKA LLC Tite 881684 [3510 § MAGUIRE R [Store l Fe] CHARGES Sima Ezvacteat [PARE rcrarge Degree iy. PaICBAL (Ci Domestic violence (Charge Desorption RAND THEFT :GREE($100,000 OR ci WY Page 1 of 2[Agencj Case Number OCPD170FF001538 [Report Date! Time 04/17/2017 02:09 PM. ‘Onense Descrigtion 44-1 FRAUD ones THAN CR. CARD/CHECK S/THEFT) [CAD incident Number OCPD17CAD021445 Enteral Case Reterence NumDer Tabasote 124 Thor AM t AM to 04/13/2017 03:00 PM _ REPORTING OFFICER / SUPERVISOR APPROVAL Reporting Omicer [Sai Nanber —] Name 1053 l STRONG, AMANDA Agproving Supenicor ss ra 254 [CORPORAL [eDWaRDS, GLEN Signature fob Sey sigrstre Page 2 of 2OCOEE POLICE DEPARTMENT STATEMENT FORM [_] CONTINUATION | Nostir: Qron ececo 1526 | PERSON MAKING STATEMENT IS: “ARRESTED? JUVENILE? : [MFVICTIM §=§/-OWNER [ }WITNESS [ }SUSPECT [ }OTHERLO (L1YES [yAXo C1YBS [NO NUM pammrameac Tae SE, | Dow AGE sisohadtistsl Stes, w | | bss | sai eve HMORLOCATED ORT [oeamenresronr_{ rETEED pa a C*d —=— = = EMPLOYER | PHONE ‘ADDRESS: cr ‘SuTE zp on OTHER - wp eie = i . See . Z A DO HEREBY VOLUNTARILY MAKE THE FOLLOWING STATEMENT WITHOUT THREAT, CORLGION, OFFER OF BENEFIT OR FAVOR BY ANY PERSONS WHOMSOEVER. TE am one oS “he mers Porkners of Moebake Lic Which is en ASsuale Neboork, ean Vkncock 16 an employee. ho Managed 000 rherne Tedvced WeSGe edhadk ganesh daly Centensre. rear Sopetkee croead Dxcendae af Io 2 he Crede§ > Vg mon Cotnpeny and Broceedd Yo ceswred vr inderag redepeh ene do Daepebye vas les oon Corp. “tre Aw QQe Wak toes ate Gaon Mobeka re gorahere erosnl $96. Shue Nw exbe. x \ing “Mn And, Teereuas ran wee \ne Soon carp. We as” a Semgens vmod \Ne AS Dress Cherges aod us AK Nest bn Covrk, SWORN TO AND SUBSCRIBED. ‘THE UNDERSIGNED AUTHORITY, I SWEAR/ AFFIRM THE ABOVE STATEMENT IS TRUE AND CORRECT. Under penalties of perjury, I declare sit Vhaye read the foregoing [document] and | THES. \ bu DAY OF, 204, that the facts stated iazit areftup aT_14aS, HOURS. aw! ‘OFFICER OR NOTARY PU + MIRANDA WARNING Wo’ ‘CHARGES ‘Way Testy Pace_l_or\ . YES[ J NO YESH] NO[] ‘YES [ NO[] Rev.05/27/2003Exhibit “F”@0000 AT&T = 5:51PM 4 63% Li )4 < Chats Jonathan Cole last seen 1 hour ago Hey buddy are you around? 9-55 pyy Yea 3:33 pmw don't mean to bug you however for some reason your Mobooka global redirect is going to us outside of FL to arandom affiliate of ours.. | think you may have someone splitting off traffic. 3:34 PM Interesting. So out global redirect is hitting a pub account on your side 3:34 PM yeah two of them if you're outside FI for us and anything international 35 PM https://www.dropbox.com/s/w7b8jrd1 w9u8daf/Screenshot%202017-04-13 %2014.51.56.png?dl=0 Dropbox Screenshot 2017-04-13 14.51.56.png . > od Shared with Dropbox 3:35 PM Vv Damn 3:35 pw g O@0000 ATAT & 5:51PM 4 63% (4 < Chats Jonathan Cole last seen 1 hour ago an affiliate 'AP Media' and 'Forsa' on our end. What are payment details 3-33 py y both chase bank in Florida https://whois.domaintools.com/65.124 .195.194/ had a login from this ip.. will send over payment details shortly Forsa LLC Chase Account Number: Routing Number: Account number: jie Routing Number: aa I'll get to the bottom of it. Jeez man | pray it is not what it looks like 3.44 pyy That is our lO 3:45 puw IP 3:45 pM.” VY WOW 23:45 Pn. @ g@0000 AT&T = 5:51PM 4 63%) 4 Jonathan Cole < Chats last seen 1 hour ago yeah &9 sorry you have to deal with that it's 100% someone there whoever has access to that voluum yea we have like 4/5 accounts on Vollum 3:46 PM / $213898 in revenue 2-47 py JESUS 3-47 puw 3grs6 voluuM 2-5; py 3grs6 what is that 3-59 pyw the account name? 2:59 py vw the voluum for your global redirect and the one the person is splitting off traffic with OK 3:52 puw got it 252 puw is there any more personal details associated with the accounts? 4:09 Pr, Vv g Q@0000 AT&T 5:51PM 4 63% Ci )4 < chats onatnan Cole © name? 4:09 puw phone? 4:09 puw email? 4:09 puw god, this pisses me off. you pay employees so much 4:10 PMY what is the date range on this traffic which was sent? 4:12 PM was it all paid out ON? 4:72 py w One sec ill get all the details 4-45 py, TY 4:16 PMV All except $7500 or so has been paid. hold that 4:76 puw Holding for now ill send it to you if anything if u feel comfortable 4.77 py y when did it start 4.4762 \/ g Q@0000 AT&T = 5:51PM 4 64% C4 < Chats Jonathan Cole last seen 1 hour ago It started with ‘AP Media’ AfflD 213872.. Contact details: https://www.dropbox.com/s/w57g4k6 zqkfghgu/Screenshot%202017-04-13 %2016.17.36.png?dl=0 .. Date Range 10/17-2:26. Dropbox Screenshot 2017-04-13 16.17.36.png > Shared with Dropbox eS 4:19 PM Then earlier this year ‘Ap Media’ aka Andreas patino introduced ‘Forsa LLC’ torun.. Their address is the same address that we both used for our offers in WY when we started them. 4:19 PM https://www.dropbox.com/s/6tsczasw 2e8w28c/Screenshot%202017-04-13 %2016.20.10.ong?dl=0 Dropbox Screenshot 2017-04-13 16.20.10.png -s oad Shared with Dropbox@0000 AT&T & 5:51PM FT 64% 4 Jonathan Cole < Chats last seen 1 hour ago One of their home IP addresses is 50.89.131.45 if you can cross reference your employee logins 4:29 pyy And 184.89.148.35 4:20 py https://wyobiz.wy.gov/business/Filing Details.aspx?eFNum=0411150381050 092212340240400601302130091121 35149 - Is Forsa °1 PM 4:21 PM Forsa is under Nathan Bennett nbforsa@gqmail.com 4:21 PM damn 4:2; puw someone is putting in work 4:29 py yw Forsa ran 2/6-this week 4.55 pyy Who went on a trip to Aruba in December? 4:22 PM during Christmas 4.95 pyy That is your leak 4.59 pry interesting 4:22 p, \“ g Q©0000 AT&T = 5:52 PM 4 64% C4 < Chats Jonathan Cole last seen 1 hour ago i know that one 4:22 py was there a log