plaintiff's 1st set of interrogatories for reality steve llc & steve carbone

8/2/2019 Plaintiff's 1st Set of Interrogatories for Reality Steve LLC & Steve Carbone

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EXHIBIT ATO

DECLARATION OF ANDREW W. DeFRANCIS

EXHIBIT ATO


Case 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 1 of 74 Page ID #:231


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NZK PRODUCTIONS INC., aCalifornia corporation, and HORIZONALTERNATIVE TELEVISION INC., aDelaware corporation,Plaintiffs,

V .

STEPHEN CARBONE, an individual,REALITY STEVE, LLC, a Texaslimited liability corporation, and DOES1 through 10, inclusive,Defendants.

CASE NO. CV11-10118 GHK (Ex)[PROPOSED] ORDER GRANTINGPLAINTIFFS' EX PARTEAPPLICATION (1) TO CONTINUEHEARING DATE ONDEFENDANTS' MOTION TODISMISS BY 60 DAYS TO PERMITJURISDICTIONAL DISCOVERY,AND (2) FOR AN ORDERPERMITTING PLA INTIFFS TOCONDUCT SUCH DISCOVERY;MEMORANDUM OF POINTS ANDAUTH ORITIES IN SUPPORTTHEREOF

Cas

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2:11-cv-10118-GHK-E Document 21 Filed 01/31/12 Page 1 of 2 Page ID #:164

FILED: 1/31/12

NOTE: CHANGES MADE BY THE COURT

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UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

Exhibit APage 4

298107 .1.docV 11-10118 G H K (E x)[PROPOSED] ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION(1) TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO DISMISS, AND(21 FOR AN ORDER PERMITTING PLAINTIFFS TO CONDUC T SUCH DISCOVERY



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ByHon. George H

2:11-cv-10118-GHK-E Document 21 Filed 01/31/12 Page 2 of 2 Page ID #:165

The Court has reviewed Plaintiffs NZK Productions Inc. and HorizonAlternative Television Inc. (collectively, "Plaintiffs") ex parte application("Application") (1) to continue the hearing date on the motion to dismiss filed byDefendants Stephen Carbone and Reality Steve, LLC (collectively, "Defendants")by sixty (60) days so that Plaintiffs may conduct jurisdictional discovery, and (2) foran order permitting Plaintiffs to conduct said jurisdictional discovery. Defendantshave filed no opposition. Having found good cause,

IT IS HEREBY ORDERED that Plaintiffs' Application is GRANTED.The hearing date on Defendants' Motion to Dismiss for Lack of Personal

Jurisdiction shall be continued from March 12, 2012, at 9:30 a.m., toMay 20 , 2012, at 9:30 a.m.In the interim, Plaintiffs are hereby permitted leave of Court to conduct

written and oral jurisdictional discovery, including but not limited to, noticingdepositions of both Defendants, propounding interrogatories, requests for admission,and requests for production, and serving subpoenas on relevant third parties for thepurposes of determining Defendants' connection with California.

Dated this 31 s t day of Jan , 2012.

Exhibit APage 5

2V11-10118 GHK (Ex)[PROPOSED] ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION(1) TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO DISMISS, AND(2 ) FOR AN ORDER PERMITTING PLAINTIFFS TO CONDUCT SUCH DISCOVERYCas12345678910111213141516171819202122232425262728 298107.1.docCase 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 3 of 74 Page ID #:233


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EXHIBIT BTO


EXHIBIT BTO




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NZK PRODUCTIONS INC., aCalifornia corporation, and H ORIZO NALTERNATIVE TELEVISION INC., aDelaware corporation,Plaintiffs,

v.STEPHEN CARBONE, an individual,REALITY STEVE, LLC, a Texaslimited liability corporation, and DOES1 through 10 , inclusive,

CASE NO . CV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONSINC.'S FIRST SET OF SPECIALINTERROGATORIES TODEFENDANT STEPHENCARBONE

Defendants.

PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC.RESPONDING PARTY:EFENDANT STEPHEN CARBONESET NO.:NEKELLEY DRYE & WARREN LL PMichael J. O'Connor (STATE BAR NO . 90017)Andrew W. DeFrancis (STATE BAR NO . 246399)10100 Santa M onica Boulevard, Twenty-Third FloorLos A ngeles, California 90067 -4008Telephone: 310) 712-6100Facsimile: 10) 712-6199moconnor kelleydrye.cornadefrancis kelleydrye.cornAttorneys for P laintiffsNZK PROD UCTIONS INC. andHORIZON ALTERNATIVETELEVISION INC. UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISIONExhibit BPage 6298408. I .docV11-10118 GHK (Ex)

PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:PLEASE TAKE NOTICE that, pursuant to Rule 33 of the Federal Rules of

Civil Procedure and Local Rule 33-2 of the United States District Court for theCentral District of California, Defendant Stephen Carbone is directed to answer inwriting and under oath each of the following interrogatories propounded by PlaintiffNZK Productions Inc. ("Interrogatories"), within the time provided by Rule 33.

SPECIAL INTERROGATORIESSPECIAL INTERROGATORY NO. 1:

IDENT IFY all PERSO NS w ho contacted YO U at [email protected] THE B ACHELO R SERIES between January 1 , 2 0 0 4, and the present.The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as toan individual, stating his or her full and customarily used names, present residentaddress, business address, and business telephone number; (b) as to any person otherthan an individual, stating its legal name and any other names used by it, the form ormanner of its organization (e.g., partnership, corpo ration, etc.), the state of itsincorporation (if it is incorporated) or the state of its formation (if it is a partnershipor limited liability company), and the address of its principal place of business;(c) as to any docum ent, its author, recipient, sender, date(s), its subject m atter, thenumber of pages therein, and wherever possible its corresponding BATESnumber(s); and (d) as to an event, transaction, or occurrence stating its date, thelocation and the manner of its occurrence (e.g., face-to-face meeting of participants,telephone calls, etc.), the identification of all its participants and eyew itnesses to itsoccurrence, its purpose and subject matter, a concise description of what transpired,and IDENTIFY any document referring to or concerning said event, transaction, oroccurrence.

The terms "PERSON" and "PERSONS," as used in these Interrogatories,shall mean all natural persons, partnerships, consortia, joint ventures, and every E x h i bother form of legally recognized entity, including corporations.ag298408.1 docV 1 1 - 1 0 1 1 8 G H K ( Ex )

PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE



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The terms "Y OU " and "Y OUR ," as used in these Interrogatories, shall meanDefendant Stephen Carbone, acting in his individual capacity or as an agent ofDefendant Reality Steve, LLC.

The term "THE BAC HEL OR SERIES," as used in these Interrogatories, shallmean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad" televisionseries.SPECIAL INTERROGA TORY NO . 2:

State the date(s) that each PE RSO N identified in response to SpecialInterrogatory N o. 1 contacted YOU .SPECIAL INTERROG ATORY NO . 3:IDEN TIFY all PERSO NS w ho YO U contacted from [email protected] THE BAC HEL OR SERIES between January 1, 2004, and the present.SPECIAL INTERROG ATORY NO . 4:

State the date(s) that YOU contacted each PERSON identified in response toSpecial Interrogatory No. 3.SPECIAL INTERROGA TORY NO . 5:

IDEN TIFY all PER SON S w ho contacted YOU at twitter.com/realitysteveconcerning THE BAC HEL OR SERIES between January 1, 2004, and the present.SPECIAL INTERROG ATORY NO . 6:

State the date(s) that each PERSON identified in response to SpecialInterrogatory N o. 5 contacted YO U.SPECIAL INTERROG ATORY NO . 7:

IDEN TIFY all PERSO NS who Y OU contacted from twitter.com/realitysteveconcerning THE BAC HEL OR SERIES between January 1, 2004, and the present.SPECIAL INTERROGA TORY NO . 8:

State the date(s) that YOU contacted each PERSON identified in response toSpecial Interrogatory No. 7.xhibit BPage 8298408.I.docV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE123456789101 11213141516171819202122232425262728Case 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 7 of 74 Page ID #:237


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SPECIAL INTERROG ATORY N O. 9:IDENT IFY each public appearance that YOU made to promote

www.realitysteve.com between January 1, 2004, and the present.SPECIAL INTERROG ATORY NO. 10:

IDENTIFY each INTERVIEW YOU gave concerning THE BACHE LORSERIES between January 1, 2004, and the present.

The term "INTERVIEW," as used in these Interrogatories, shall mean anytype of m edia appearance, including but not limited to television, radio, print, orother type of media appearance.SPECIAL INTERROGATORY NO. 11:IDENT IFY each ARTICLE that YOU authored concerning THEBAC HELO R SER IES between January 1, 2004, and the present.

The term "ARTICLE," as used in these Interrogatories, shall mean anywriting that appears on the internet, in an em ail or print newsletter, in a newspaper,in a magazine, or in any o ther print publication.SPECIAL INTERROGATORY NO. 12:

IDENT IFY each PERSON from whom Y OU received any informationconcerning THE BAC HELO R SE RIES between January 1, 2004, and the present.SPECIAL INTERROGATORY NO. 13:

For each of the PERSONS identified in response to Special Interrogatory No.12, state the date(s) each PERSO N provided YO U w ith information about THEBACHELOR SERIES.SPECIAL INTERROGATORY NO. 14:

IDENT IFY all communications that YOU initiated with any PERS ON who isor was a resident of California concerning THE BAC HELO R SE RIES.SPECIAL INTERROGATORY NO. 15:

IDENT IFY all communications that YO U initiated with any PERSON who isor was a resident of California concerning www.realitysteve.com298408. I .docV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE xhibi

Pa e

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SPECIAL INTERROG ATORY NO. 16:IDENT IFY all comm unications that YOU received from any PER SON who

is or was a resident of California concerning THE BA CHE LOR SERIES.SPECIAL INTERROGA TORY NO. 17:

IDENT IFY all communications that YOU received from any PERSON whois or was a resident of California concerning ww w.realitysteve.comSPECIAL INTERROGA TORY N O. 18:

IDEN TIFY all trips that YOU made to California between January 1, 2004,and the present.SPECIAL INTERROGA TORY NO. 19:For each of the trips identified in response to Special Interrogatory No. 18,IDENTIFY where you stayed while visiting California.SPECIAL INTERROGATORY NO. 20:

Describe the pu rpose of each of the trips identified in response to SpecialInterrogatory No. 18.SPECIAL INTERROGA TORY NO. 21:

IDENTIFY all real estate that YOU own in California, including any realestate that you jointly ow n w ith another PERSON .SPECIAL INTERROGATORY NO. 22:

IDENT IFY all bank accounts that YOU own or control in California.SPECIAL INTERROGATORY NO. 23:

IDENTIFY all sources of income that YOU derive from California, includingall income derived from PE RSO NS who reside in California.SPECIAL INTERROGATORY NO. 24:

IDENT IFY each time that YO U p aid income taxes in California betweenJanuary 1, 2004, and the present./ / /x h i b i t BPage 10123456789101 1121 3141 516171 819202122232425262728 298408 .1 . doc 4V11-10118 GHK (Ex)

PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARB ONE



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SPECIAL INTERROGATORY NO. 25:IDENT IFY each time that YOU voted in an ELEC TION as a California

resident between January 1, 2004, and the present.The term "ELECT ION", as u sed in these Interrogatories, shall mean any type

of political election, including local, statewide, and n ational elections.

DAT ED: February 7, 2012ELLEY DRYE & WARREN LL PMichael J. O'ConnorAndrew W . DeFrancisBy C4!g2hAndrew W. FrancisAttorneys for Plain s NZK Productions Inc.and Horizon Alternative Television Inc.

Exhibit BPage 11

298408. I .docV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE

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PROOF OF SERVICESTATE OF CALIFORNIA, COUNTY OF LOS ANGELES

At the time of service, I was over 18 years of age and not a party to thisaction. I am employed in the County of Los Angeles, State of California. Mybusiness address is 10100 Santa Monica Boulevard, Twenty-Third Floor, LosAngeles, California 9006 7.On F ebruary 7, 2012, I served a true copy of the foregoing docum entdescribed as PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OFSPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONEon the interested parties in this action as follows:D. B radley Kizzia, Esq.Brown Fox K izzia & Johnson PLLC8226 Do uglas Avenue, Suite 411Dallas, TX 75225Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC Gregg A . Farley, Esq.Law O ffices of Gregg A . Farley11755 Wilshire Boulevard, Suite 1845Los Angeles, CA 90025Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLCBY FEDERAL EXPRESS: I enclosed said document in an envelope orpackage provided by Federal Express and addressed to the persons at the addresseslisted in the Service List. I_placed the envelope or package for co llection andovernight delivery at an office or a regularly utilized drop box o f Federal Express ordelivered such docum ent to a courier or driver authorized by Federal Express toreceive documents.

FEDERAL: I declare under penalty of perjury under the laws of theUnited States of America that the foregoing is true and correct and that I amemployed in the office of a member of the bar of this Court at whose direction theservice was m ade.Executed on February 7, 2012, at Los Angeles, California.

Exhibit BPage 12

298408.! .docV11-10118GHK (Ex)PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT STEPHEN CARBONE

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EXHIBIT CTO


EXHIBIT CTO




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NZK PROD UCTIONS INC., aCalifornia corporation, and HORIZO NALTERN ATIVE TELEVISION INC., aDelaware corporation,Plaintiffs,

V .STEPHEN CARBO NE, an individual,REALITY STEV E, LLC, a Texaslimited liability corporation, and DO ES1 through 10 , inclusive,

CASE NO. CV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONSINC.'S FIRST SET OF SPECIALINTERROGATORIES TODEFENDANT REALITY STEVE,LLC

Defendants.

PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC.RESPONDING PARTY:EFENDANT REALITY STEVE, LLCSET NO.:NEKELLEY DRYE & WARREN LLPMichael J. O'Connor (STATE BAR NO . 90017)Andrew W . DeFrancis (STATE BAR N O. 246399)10100 Santa M onica Boulevard, Twenty-Third FloorLos Angeles California 90067-4008Telephone: 310) 712-6100Facsimile: 10) 712-6199moconnor kelleydrye.cornadefrancis kelleydrye.cornAttorneys for PlaintiffsNZK PROD UCTIONS INC. andHORIZON ALTERNATIVETELEVISION INC. UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISIONExhibit CPage 13298409.1.docV11-10118 GHK (Ex)

PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT REALITY STEVE, LLC

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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:PLEA SE TA KE N OTICE that, pursuant to Rule 33 of the Federal Rules of

Civil Procedure and Local Rule 33-2 of the United States District Court for theCentral District of California, Defendant Reality Steve, LLC is directed to answer inwriting and under oath each of the following interrogatories propounded by PlaintiffNZK Productions Inc. (the "Interrogatories"), within the time provided by R ule 33.

SPECIAL INTERROGATORIESSPECIAL INTERROGA TORY NO. 1:

IDENTIFY each PERSON with whom YOU registeredwww.realitysteve.com between January 1, 20 04, and the present.The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as toan individual, stating his or her full and customarily used names, present residentaddress, business address, and business telephone n umb er; (b) as to any person otherthan an individual, stating its legal name and any other nam es used by it, the form ormanner of its organization (e.g., partnership, corporation, etc.), the state of itsincorporation (if it is incorporated) or the state of its formation (if it is a partnershipor limited liability com pany), and the address of its principal place of business;(c) as to any d ocum ent, its author, recipient, sender, date(s), its subject m atter, thenumber of pages therein, and w herever possible its corresponding BATE Snum ber(s); and (d) as to an even t, transaction, or occurrence stating its date, thelocation and the m anner of its occurrence (e.g., face-to-face meeting of participants,telephone calls, etc.), the identification of all its participants and ey ewitnesses to itsoccurrence, its purpose and subject matter, a concise description of what transpired,and IDENTIFY any document referring to or concerning said event, transaction, oroccurrence.

The terms "PER SON " and "PER SON S," as used in these Interrogatories,shall mean all natural persons, partnerships, consortia, joint ventures, and every E x h i bother form of legally recogn ized entity, including corporations.age298409 1 docV1I-10118 GHK (Ex)


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The terms "YOU," "YOU R," or "DEFE ND ANT ," as used in theseInterrogatories, shall mean Defendant Reality Steve, LLC and each of its past andpresent agents, associates, manag ers, representatives, accoun tants, attorneys, andanyone else acting, or w ho has acted, on its behalf, including Defendant StephenCarbone.SPECIAL INTERROGA TORY NO . 2:

State the date(s) YO U registered ww w.realitysteve.com with each of thePERSONS identified in response to Special Interrogatory No. 1.SPECIAL INTERROG ATORY NO . 3:

IDENTIFY each PERSO N who H OSTED ww w.realitysteve.com betweenJanuary 1, 2004, and the present.

The term "HOSTED," as used in these Interrogatories, shall mean the act ofproviding server space, internet services, and/or file maintenanc e for websites.SPECIAL INTERROGA TORY NO . 4:

State the date(s) that each PE RSO N identified in response to SpecialInterrogatory No. 3 HO STED ww w.realitysteve.com .SPECIAL INTERROG ATORY NO . 5:

IDEN TIFY all agreements of any kind entered into between January 1, 2004,and the present concerning advertising on www.realitysteve.com .SPECIAL INTERROG ATORY NO . 6:

IDENT IFY all PERS ON S who have purchased advertising onwww.realityseteve.com between January 1, 2004 , and the present.SPECIAL INTERROG ATORY NO . 7:

State all username accounts registered on www.realitysteve.com .SPECIAL INTERROGA TORY NO . 8:

For each of the username accounts identified in response to SpecialInterrogatory No. 7, state the email address affiliated with each accoun t.xhibit CPage 15298409.1.docV11-10118 GHK (Ex)


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SPECIAL INTERROGATORY NO. 9:IDEN TIFY all PERSO NS who have a contractual relationship of any kind

with www.realitysteve.com .SPECIAL INTERRO GATO RY NO. 10:

Describe YO UR contractual relationship with each PE RSO N identified inresponse to Special Interrogatory No. 9.SPECIAL INTERRO GATO RY NO. 11:

IDEN TIFY all mem bers of Reality Steve, LLC from January 1, 2004, throughthe present.SPECIAL INTERRO GATO RY NO. 12:

For each of the P ERSO NS identified in response to Special Interrogatory N o.11, state the date(s) each PER SON was a mem ber of Reality Steve, LLC .SPECIAL INTERRO GATO RY NO. 13:

State the monthly number of visitors to www.realitysteve.com betweenJanuary 1, 2004, and the present.SPECIAL INTERRO GATO RY NO. 14:

State the monthly number of visits to www.realitysteve.com by PERSONSlocated in California between January 1, 2004, and the present.SPECIAL INTERRO GATO RY NO. 15:

State the monthly number of visits to www.realitysteve.com by computerslocated in California between January 1, 2004, and the present.SPECIAL INTERRO GATO RY NO. 16:

IDEN TIFY all bank accounts that YO U ow n or control in California.SPECIAL INTERRO GATO RY NO. 17:

IDEN TIFY all sources of income that YO U derive from C alifornia, includingall income derived from PER SON S w ho reside in California./ / /xhibit C/ / /age 16123456789101 1121 3141516171819202122232425262728 298409.1.doc CV11-10118 GH K (Ex)




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SPECIAL INTERROGATORY NO. 18:IDENT IFY each time that YO U paid income taxes in California between

January 1, 2004, an d the present.SPECIAL INTERROGATORY N O. 19:

IDENT IFY all trips to California made on behalf of YOU between January 1,2004, and the present.SPECIAL INTERROGATORY NO. 20:

Describe the purpose of each of the trips identified in response to SpecialInterrogatory No. 19.SPECIAL INTERROGATORY N O. 21:IDENT IFY each PERSON from whom YO U received any informationconcerning THE B ACH ELO R SER IES between January 1, 2004, and the present.

The term "THE BAC HEL OR SERIES," as used in these Interrogatories, shallmean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad" televisionseries.SPECIAL INTERROGATORY NO. 22:

For each of the PERSONS identified in response to Special Interrogatory No.21, state the date(s) that each PERSO N provided Y OU with information about THEBACHELOR SERIES.SPECIAL INTERROGATORY NO. 23:

IDENT IFY each public appearance that YOU made to promotewww.realitysteve.com between January 1, 200 4, and the present.SPECIAL INTERROGATORY NO. 24:

IDENT IFY each member of YOUR m ember Yea! Network, LLC, asidentified at page 7 of YOUR MOTION TO DISMISS.

The term "M OTION TO DISM ISS," as used in these Interrogatories, shallmean D efendants Stephen Carbone and R eality Steve, LLC's Motion to Dismiss for

ExhibLack of Personal Jurisdiction in this matter, filed on January 20, 2012.1 398409 1.docV11-10118 GHI aEx


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SPECIAL INTERROGATORY NO. 25:For each of the PERS ON S identified in response to Special Interrogatory No.

24, state the date(s) each PERSO N w as a member of Yea! Netw ork, LLC.

DATED: February 7, 2012ELLEY DRYE 8 . E . WARREN LL PMichael J. O'ConnorAndrew W . DeFrancisByAndrew W .ancisAttorneys for Plainti NZK Productions Inc.and H orizon Alternative Television Inc.Exhibit CPage 18

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PROOF OF SERVICESTATE OF CALIFORNIA, COUNTY OF LOS ANGELES

At the time of service, I was over 18 years of age and not a party to thisaction. I am employed in the County of Los Angeles, State of California. Mybusiness address is 10100 Santa Monica Boulevard, Twenty-Third Floor, LosAngeles, California 9006 7.

On February 7, 2012, I served a true copy of the foregoing docum entdescribed as PLAINTIFF NZK PRODUCTIONS INC.'S- FIRST SET OFSPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLCon the interested parties in this action as follows:Gregg A . Farley, Esq.Law O ffices of Gregg A . Farley11755 Wilshire Boulevard, Suite 1845Los Angeles, CA 90025Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

BY FEDERAL EXPRESS: I enclosed said document in an envelope orpackage provided by Federal Express and addressed to the persons at the addresseslisted in the Service List. I_placed the envelope or package for co llection andovernight delivery at an office or a regularly utilized drop box of Federal Express ordelivered such docum ent to a courier or driver authorized by Federal Express toreceive documents.FEDERAL: I declare under penalty of perjury under the laws of theUnited States of America that the foregoing is true and correct and that I amemployed in the office of a member of the bar of this Court at whose direction theservice was m ade.

Executed on February 7, 2012, at Los Angeles, California.

--..'aren M. jaden

Exhibit CPage 19

298409 I docV11-10118 GHK (Ex)PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESTO DEFENDANT REALITY STEVE, LLC

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D. Bradley K izzia, Esq.Brown Fox Kizzia & Y ohnson PLLC8226 D ouglas Avenue, Suite 411Dallas, TX 75225Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

E 3



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EXHIBIT DTO


EXHIBIT DTO




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NZK PRODUCTIONS INC., aCalifornia corporation, and H ORIZO NALTERNATIVE TELEVISION INC., aDelaware corporation,Plaintiffs,

V .STEPHEN CARBONE, an individual,REALITY STEV E, LLC, a Texaslimited liability corporation, and DOES1 through 10, Inclusive,

Defendants.

Attorneys fo r PlaintiffsNZK PROD UCTIONS INC. andHORIZON ALTERNATIVETELEVISION INC.


CASE NO. CV11-10118 GHK (Ex)NOTICE OF DEPOSITION OFDEFENDANT STEPHENCARBONEDate:Time:Place:

April 4, 20129:00 a.m.Quilling, Selander, Low nds,W inslett & M oser, P.C.2001 B ryan Street, Ste. 1800Dallas, TX 75 201

KELLEY DRYE & WARREN LL PMichael J. O'Connor (STATE BAR NO. 90017)Andrew W . DeFrancis (STATE BAR N O. 246399)10100 Santa M onica Boulevard, Twenty-Third FloorLos Angeles California 90067-4008Telephone: 310) 712-6100Facsimile: 10) 712-6199moconnor kelleydrye.comadefrancis kelleydrye.com

298976.1.doc

Exhibit DPage 20

CV11-10118 GHK (Ex)NOTICE OF DEPOSITION OF DEFENDAN T STEPHEN CARD ONE

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:PLEA SE TA KE N OTICE that, pursuant to Rule 30 of the Federal Rules of

Civil Procedure, Plaintiffs NZK Productions Inc. and Horizon AlternativeTelevision Inc. (collectively, "Plaintiffs") will conduct the deposition of DefendantStephen Carbone on April 4, 2012, at 9:00 a.m. at the offices of Quilling, Selander,Lownds, W inslett & M oser, P.C., 2001 Bryan S treet, Suite 1800, D allas, Texas75201.

The deposition will be conducted upon oral examination and will be recordedstenographically and/or by videotape before a certified shorthand reporter, notarypublic or other person authorized by law to take depositions and adm inister oathsand will continue from day to day, excluding Sundays and holidays, untilcompleted.

PLEA SE TA KE FU RTH ER N OTICE that Plaintiffs reserve the right torecord the testimony of this deponent by stenographic method through the use ofrealtime and w ill provide rough draft transcripts, if requested.

DATED : March 6, 2012ELLEY DRYE & WARREN LLPMichael J. O'ConnorAndrew W . DeFrancisByAndrew W FrancisAttorneys for Plaintiffs NZK Productions Inc.and Horizon Alternative Television Inc.Exhibit DPage 21

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PROOF OF SERVICESTATE OF CALIFORNIA, COUNTY O F LOS ANG ELES

At the time of service, I was ov er 18 years of age and not a party to thisaction. I am emp loyed in the County of Los A ngeless State of California. Mybusiness address is 10100 Santa M onica Boulevard, Tw enty-Third Floor, LosAngeles, California 90067.

On M arch 6, 2012, I served a true copy of the foregoing document describedas NOTICE OF DEPOSITION OF DEFENDAN T STEPHEN CARBONE onthe interested parties in this action as follows:Gregg A . Farley, Esq.Law Offices of Gregg A . Farley11755 W ilshire Boulevard, Suite 1845Los Angeles CA 90025Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

BY FEDERAL EXPRESS: I enclosed said docum ent in an envelope orpackage provided by Federal Express and addressed to the persons at the addresseslisted in the Service L ist. I_placed the enve lope or package for collection andovernight delivery at an o ffice or a . regularly utilized drop box o f Federal Express ordelivered such docum ent to a courier or driver authorized by Federal Express toreceive documents.FEDERAL: I declare under penalty of perjury under the laws of theUn ited States of A merica that the foregoing is true and correct and that I amemployed in the office of a m ember of the ba r of this Court at whose direction theservice was made.

Executed on M arch 6, 2012, at Los Angeles, California.

Karen M. 'Ijaden

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D. Bradley K izzia, Esq.Brown Fox K izzia & Johnson PLLC8226 Doug las Avenue, Suite 411Dallas, TX 75225Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

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NZK PRODUCTIONS NC aCalifornia corporation, and H ORIZO NALTERNATIVE TELEVISION NC., aDelaware corporation,Plaintiffs,

V .STEPHEN CARBONE, an individual,REALITY STEV E, LLC, a Texaslimited liability corporation, and DOES1 through 10, inclusive,

Defendants.

KELLEY DRYE & WARREN LL PMichael J. O'Connor (STATE BAR NO . 90017)Andrew W . DeFrancis (STATE BAR N O. 246399)10100 Santa M onica Boulevard, Twenty-Third FloorLos Angeles California 90067-4008Telephone: 310) 712-6100Facsimile: 10) [email protected] kelleydrye.cornAttorneys for PlaintiffsNZK PRO DUC TIONS INC. andHORIZON ALTERNATIVETELEVISION INC.


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CASE NO. CV11-10118 GHK (Ex)NOTICE OF DEPOSITION OFDEFENDANT REALITY STEVE,LLC PURSUANT TO RULE 30(B)(6)OF THE FEDERAL RULES OFCIVIL PROCEDUREDate:Time:Place:

April 4, 20122:00 p.m.Selander, Low nds,W inslett & M oser, P.C.2001 Bryan S treet, Ste. 18 00Dallas, TX 75 201

Exhibit DPic 21

298975.1.docV11-10118 GHK (Ex)NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLCPURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURECase 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 24 of 74 Page ID #:254


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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:PLEA SE TA KE N OTICE that, pursuant to Rule 30(b)(6) of the Federal Rules

of Civil Procedure, Plaintiffs NZK Productions Inc. and Horizon A lternativeTelevision Inc. (collectively, "Plaintiffs") will conduct the deposition of DefendantReality Steve, LLC o n A pril 4, 2012, at 2:00 p.m. at the offices of Qu illing,Selander, Lownds, W inslett & Mo ser, P.C., 2001 B ryan Street, Suite 1800, Dallas,Texas 75201. R eality Steve, LLC shall designate one or m ore of its officers,directors, employees or o ther persons who shall testify as to all matters known orreasonably available to it with regard to the topics in Attachment A hereto.

The dep osition will be conducted upon oral examination and will be recordedstenographically and/or by v ideotape before a certified shorthand reporter, notarypublic or other person authorized by law to take depositions and administer oathsand w ill continue from day to day, excluding Sundays and ho lidays, untilcompleted.

PLEA SE TA KE F URT HER NOT ICE that Plaintiffs reserve the right torecord the testimony of this deponent by stenographic method through the use ofrealtime and will provide rough draft transcripts, if requested.

DATED : March 6, 2012ELLEY DRYE & WARREN LLPMichael J. O'ConnorAndrew W . DeFrancisBy 6;2Andrew W FrancisAttorneys for Plain fs NZK Productions Inc.and H orizon Alternative Television Inc.Exhibit DPage 24

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NOTICE OF DEPOSITION OF DEFENDANT REALITY STEV E, LLCPURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE



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ATTACHMENT ADEFINITIONS

"REAL ITY ST EVE , LLC," as used herein, shall mean Defendant RealitySteve, LLC, including the agents, attorneys, employees, officers, representatives,directors, consultants, or others acting on (or who acted on ) its behalf.

TOPICSTOPIC NO. 1:

REA LITY STEV E, LL C's contracts with third-parties, particularly thoselocated in California.TOPIC NO. 2:

REA LITY S TEVE , LLC's involvement in the creation and operation of thewebsite located at www.realitysteve.com .TOPIC NO. 3:

Reality Steve, LLC's revenue and incom e, as well as the sources whereby thatrevenue and income is derived.TOPIC NO. 4:

Reality Steve, LLC's tax returns, from January 1, 2004, through the present.TOPIC NO. 5:

Reality Steve, LLC's involvement in any lawsuits, from January 1, 2004,through the presentTOPIC NO. 6:

The office locations of Reality Steve, LL C.TOPIC NO. 7:

Property owned by o r on behalf of Reality Steve, LLC.TOPIC NO. 8:

The officers and memb ers of Reality Steve, LLC .E x h i b i t DTOPIC NO. 9: Page 25The formation and corporate structure of Reality Steve, LLC.123456789101 11213141 516171819202122232425262728 298975.1.doc 1V11-10118 GH K (Ex)ATTACHMENT ACase 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 26 of 74 Page ID #:256


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TOPIC NO . 10:Travel undertaken on behalf of Reality Steve, LLC , including travel to

promote the w ebsite located at w ww .realitysteve.com .TOPIC NO . 11:

Contacts between REAL ITY ST EVE, LLC and residents of or companieslocated in California.

Exhibit DPage 26

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PROOF OF SERVICESTATE OF CALIFORNIA, COUNTY O F LOS ANGELES

At the time of service, I was ov er 18 years of age and not a party to thisaction. I am employed in the County of Los Angeles State of Cahfornia. Mybusiness address is 10100 S anta Monica B oulevard, Tw enty-Third Floor, LosAngeles, California 900 67.

On March 6 , 2012, I served a true copy of the foregoing, document describedas NOTICE OF DEPOSITION OF DEFENDA NT REALITY STEVE, LLCPURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVILPROCEDURE on the interested parties in this action as follows:Gregg A . Farley, Esq.Law O ffices of Gregg A. Farley11755 Wilshire Boulevard, Suite 1845Los Angeles, CA 90025Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

BY FEDERA L EXPRESS: I enclosed said docum ent in an envelope orpackage provided by Federal Express and addressed to the persons at the addresseslisted in the Service List. I_placed the envelop e or package for collection andovernight delivery at an office or a regularly utilized drop box of Federal E xpress ordelivered such docum ent to a courier or driver authorized by F ederal Express toreceive d ocuments.FEDERAL: I declare under penalty of perjury under the laws of theUnited States of Am erica that the foregoing is true and correct and that I amemployed in the office of a member of the - bar of this Court at whose d irection theservice was made.

Executed on M arch 6, 2012, at Los Angeles, California.

L4 LJKaren M. aden

Exhibit DPage 27

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D. B radley Kizzia, Esq.Brown Fox K izzia & Johnson PLLC8226 D ouglas Avenue, Suite 411Dallas, TX 75225Fax: [email protected] for defendants StephenCarbo ne and Rea lity Steve, LLC

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EXHIBIT ETO


EXHIBIT ETO




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Gregg A. Farley, SBN 115593LAW OFFICES OF GREGG A . FARLEY11755 W ilshire Blvd., Ste. 1845Los Angeles, CA 90025Telephone: (310) 445-4024Facsimile: (310) 445 [email protected]. Bradley K izzia (Pro Hac Vice)BROWN FOX KIZZIA & JOHNSON PLLC8226 Dou glas Avenue, Suite 411Dallas, Texas 75225Telephone: (469) 893-9940Facsimile: (214) 613-333 [email protected] for DefendantsSTEPHEN CARBONEand REALITY STEVE, LLC


NZK PRODUCTIONS INC., aCalifornia corporation, and HORIZON )ALTERNATIVE TELEVISION INC., a) Case No.: CV11-10118-GHK (Ex)Delaware corporation,Plaintiffs,V S.EFENDANT STEPHENCARBONE'S RESPONSES TOSTEPHEN CARBONE, an individual, PLAINTIFF NZK PRODUCTIONSand REALITY STEVE, LLC, a TexasNC.'S FIRST SET OF SPECIALlimited liability corporation,NTERROGATORIESDefendants.rExhibit E.-1-age 28STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES1235678910111213141516171819202122232425262728 Case 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 30 of 74 Page ID #:260


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PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC.RESPONDING PARTY:EFENDANT STEPHEN CARBONESET NO.:NE

Exhibit E-2 -age 29

STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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The terms "PERSON" and "PERSONS," as used in these Interrogatories,shall mean all natural persons, partnerships, consortia, joint ventures, and everyother form of legally recognized entity, including corporations.

The terms "YOU," "YOUR," or " DEFENDANT," as used in theseInterrogatories, shall mean Defendant Stephen Carbone, acting in his individualcapacity or as an agent of D efendant Reality Steve, LLC .

The term "THE BACHELOR SERIES," as used in these Interrogatories,shall mean "The Bachelor," "The 13achelorette" and/or the "Bachelor Pad"television series.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I havemade or received any communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011. However,

-4 -STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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on or about October 24, 2011, November 16, 2011 and November 18, 2011,Defendant sent three electronic communications to the following persons who doNOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer.However, no responsive information was received.SPECIAL INTERROGA TORY NO . 2:

State the date(s) that each PERSON identified in response to SpecialInterrogatory No. 1 contacted YOU .ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, on or about October 24, 2011, November 16, 2011 andNovember 18, 2011, Defendant sent three electronic communications to thefollowing persons who do NOT live in California: Jaclyn Swartz, Emily O'Brienand Casey Shteamer. However, no responsive information w as received.

Exhibit E-5-age 32


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SPECIAL INTERROGATORY NO. 3:IDENTIFYllERSONShoOU contactedro [email protected] concerning THE BACHELOR SERIES between January

1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I havemade or received any communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011.However, on or about October 24, 2011, November 16, 2011 and November 18,2011, Defendant sent three electronic communications to the following personswho do NOT live in California: Jaclyn Swartz, Emily O'Brien and CaseyShteamer. However, no responsive information was received.

Exhibit E-6-age 33


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SPECIAL INTERROGA TORY NO . 4:State the date(s) that you contacted each PERSON identified in response to

Special Interrogatory NO . 3.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, on or about October 24, 2011, November 16, 2011 andNovember 18, 2011, Defendant sent three electronic communications to thefollowing persons who do NOT live in California: Jaclyn Swartz, Emily O'Brienand Casey S hteamer. However, no responsive information was received.SPECIAL INTERROGATORY NO. 5:

IDENTIFY all PERSONS who contacted YOU at twitter.com/realitysteveconcerning THE BACHELOR SERIES between January 1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that is

-7-STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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relevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I havemade or received any communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011.However, on or about October 24, 2011, November 16, 2011 and November 18,2011, Defendant sent three electronic communications to the following personswho do NOT live in California: Jaclyn Swartz, Emily O'Brien and CaseyShteamer. However, no responsive information was received.SPECIAL INTERRO GATOR Y NO. 6:

State the date(s) that each PERSON identified in response to SpecialInterrogatory No. 5 contacted YOU .ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information not

-8 -STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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reasonably calculated to lead to admissible evidence and information that isproprietary and sub ject to the journalistic privilege. Sub ject to these objections andwithout waiving same, on or about October 24, 2011, November 16, 2011 andNovember 18, 2011, Defendant sent three electronic communications to thefollowing persons who do NOT live in California: Jaclyn Swartz, Emily O'Brienand C asey Shteamer. How ever, no responsive information was received.SPECIAL INTERRO GATOR Y NO. 7:

IDENTIFY allERSONSho YOUontactedromtwitter.com/realitysteve concerning THE BACHELOR SERIES between January1, 2004, and the present.ANSWER:Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I havemade or received any communications with residents of California about non-

-9 -STEPHEN CARI3ONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

Exhibit EPage 36

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public information concerning the Bachelor series since January 1, 2011.However, on or about October 24, 2011, November 16, 2011 and November 18,2011, Defendant sent three electronic communications to the following personswho do NOT live in California: Jaclyn Swartz, Emily O'Brien and CaseyShteamer. How ever, no responsive information w as received.SPECIAL INTERRO GATOR Y NO. 8:

State the date(s) that YOU contacted each P ERSO N identified in response toSpecial Interrogatory N o. 7 .ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, on or about October 24, 2011, November 16, 2011 andNovember 18, 2011, Defendant sent three electronic communications to thefollowing persons who do NOT live in California: Jaclyn Swartz, Emily O'Brienand C asey Shteamer. How ever, no responsive information was received.

-10-STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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SPECIAL INTERROGA TORY NO . 9:IDENTIFY each public appearance that YOU made to promote

www.realitysteve.com between January 1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad andnot reasonably limited to information that is relevant to Defendant's objection tojurisdiction in California. Subject to the foregoing objections and without waiving

same, Defendant responds as follows:Appearance on WFAA Channel 8 in Dallas, Texas on March 14, 2011.Appearance at Bailey's Prime Plus in Dallas, Texas on March 14, 2011.Three (3) additional appearances on WFAA Channel 8 in Dallas, Texas.

SPECIAL INTERROGATORY NO. 10:IDENTIFY each INTERVIEW YOU gave concerning THE BACHELOR

SERIES between January 1, 2004, and the present.The term "INTERVIEW," as used in these Interrogatories, shall mean any

type of media appearance, including but not limited to television, radio, print, orother type of media appearance.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad andnot reasonably limited to information that is relevant to Defendant's objection to


Exhibit EPage 38



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jurisdiction in California. Subject to the foregoing objections and without waivingsame, see Answer to Special Interrogatory No. 9. Additionally, there were variousradio interviews, but none in California.SPECIAL INTERROGATORY NO. 11:

IDENTIFY each ARTICLE that YOU authored concerning THEBAC HELO R SER IES between January 1, 2004, and the present.

The term "ARTICLE," as used in these Interrogatories, shall mean any

writing that appears on the intemet, in an email or print newsletter, in a newspaper,in a m agazine, or in any other print publication.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad andnot reasonably limited to information that is relevant to Defendant's objection tojurisdiction in California. Subject to the foregoing objections and without waivingsame, see w ww .realitysteve.com .SPECIAL INTERROGATORY NO. 12:

IDENTIFY each PERSON from whom YOU received any informationconcerning THE BACHELOR SERIES between January 1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that is

-12-STEPHEN CARBONE'S RESPONSES TONZK PRODUCTIONS, INC. 'S FIRST SET OF SPECIAL INTERROGATORIES

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relevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I havemade or received any communications with residents of California about non-

public information concerning the Bachelor series since January 1, 2011.SPECIAL INTERROGATORY NO. 13:

For each of the PERSONS identified in response to Special InterrogatoryNo. 12, state the date(s) each PERSON provided YOU with information aboutTHE BACHELO R SERIES.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, see A nswer to Special Interrogatory N o. 12.

-13-STEPHEN CARBONE'S RESPONSES TO

NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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SPECIAL INTERROGATORY N O. 14:IDENTIFY a ll communications that YOU initiated with any PERSON who

is or was a resident of California concerning the BAC HE LOR SER IES.ANSWER:

I do not recall any names, dates or details of possible communications withCalifornia residents years go, but I do not believe I have made or received anycommunications with residents of California about non-public informationconcerning the Bachelor series since January 1, 2011.SPECIAL INTERROGATORY NO. 15:

IDENTIFY all communications that YOU initiated with any PERSON whois or was a resident of California concerning ww w.realitysteve.com .ANSWER:

I do not recall any names, dates or details of possible communications withCalifornia residents years go, but I do not believe I have made or received anycommunications with residents of California about non-public informationconcerning the Bachelor series since January 1, 2011.SPECIAL INTERROG ATORY N O. 16:

IDENTIFY all communications that YOU received from any PERSON whois or was a resident of California concerning TH E BA CHE LOR SER IES.

-14-STEPHEN CARBONE'S RESPONSES TO

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ANSWER:I do not recall any names, dates or details of possible communications with

California residents years go, but I do not believe I have made or received anycommunications with residents of California about non-public informationconcerning the Bachelor series since January 1, 2011.SPECIAL INTERR OGATOR Y NO. 17:

IDENTIFY all communications that YOU received from any PERSON who

is or was a resident of California concerning www.realitysteve.com .ANSWER:I do not recall any names, dates or details of possible communications withCalifornia residents years go, but I do not believe I have made or received anycommunications with residents of California about non-public informationconcerning the Bachelor series since January 1, 2011.SPECIAL INTERR OGATOR Y NO. 18:

IDENTIFY all trips that you made to California between January 1, 2004,and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad andunduly burdensome. Subject to these objections and without waiving same,

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Defendant visited California approximately five (5) six (6) times per year fromJanuary 1 , 2006 through the present.

3SPECIAL INTERROGATO RY NO. 19:

4For each of the trips identified in response to Special Interrogatory No. 18,

IDENT IFY where you stayed while visiting California.7

ANSWER:Defendant objects to this Special Interrogatory because it is overbroad and

1 0unduly burdensome. Subject to these objections and without waiving same, in theHuntington Beach area with family or in hotels.

1 3 SPECIAL INTERROGATO RY NO. 20:1 4

Describe the purpose of each of the trips identified in response to SpecialInterrogatory No . 1 8.

1 7ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad and20 unduly burdensome. Subject to these objections and without waiving same, the21

trips to California were personal and not for business. Instead, they were forbirthdays, vacations, and/or to visit family.

24 SPECIAL INTERROGATO RY NO. 21:IDENTIFY all real estate that YOU own in California, including any real

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ANSWER:Defendant does not own any real estate in California.

SPECIAL INTERRO GATO RY NO . 22:IDENT IFY all bank accounts that YOU own or control in California.

ANSWER:Defendant does not ow n or control any bank accounts in California.

SPECIAL INTERROGATORY NO. 23:

IDENTIFY all sources of income that YOU derive from California,including all income derived from PER SON S w ho reside in California.ANSWER:

Defendant does not derive any income from California.SPECIAL INTERROGATORY NO. 24:

IDENTIFY each time that YOU paid income taxes in California betweenJanuary 1, 2004, and the present.ANSWER:

Defendant has not paid income taxes in California between January 1, 2004and the present.SPECIAL INTERROGATORY NO. 25:

IDENTIFY each time that YOU voted in an ELECTION as a Californiaresident between January 1 , 2004, and the present. Exhibit E

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/r. FarleyAttorneys for Defendants Stephen Carboneand Reality Steve, LLCBy:The term "ELECTION," as used in these Interrogatories, shall mean anytype of political election, including local, statewide, and n ational elections.ANSWER:Defendant has not voted in an election as a California resident betweenJanuary 1, 2004 and the present.DATED: March 0,- -2012 BROW N FOX KIZZIA & JOHNSON PLLCBy: D. B radley Kizzia (P)Attorneys for De endanphen Carboneand Reality Steve, LLCDATED: March2012 LAW OFFICES OF GREGG A. FARLEY12345678910111213141516171819202122232425

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Gregg A . Farley, SBN 115593 (local counsel)LAW OFFICES OF GREGG A. PARLEY11755 W ilshire Blvd., Ste. 1845Los Angeles, CA 90025Telephone: (310) 445-4024Facsimile: (310) [email protected]. Bradley Kizzia (Pro Hac Vice)BROWN FOX KIZZIA & JOHNSON PLLC8226 Douglas Avenue, Suite 411Dallas, Texas 75225Telephone: (469) 893-9940Facsimile: (214) [email protected]

NZK PRODUCTIONS INC., aCalifornia corporation, and HORIZON )ALTERNATIVE TELEVISION INC., a)Delaware corporation,Plaintiffs,

VS.

STEPHEN CARBONE, an individual,and REALITY STEVE, LLC, a Texaslimited liability corporation,Defendants.

Case No.: CV11-10118-GHK (Ex)

Attorneys for DefendantsSTEPHEN CARBONEand REALITY STEVE, LLC


)

DECLARATION OF STEPHENCARBONE IN SUPPORT OFREALITY STEVE, LLC'SRESPONSES TO NZKPRODUCTIONS, INC.'S FIRST SETOF SPECIAL INTERROGATORIES

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DECLARATION OF STEPHEN CARBONE-1 - Exhibit E

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DECLARATION OF STEPHEN CARBONEI, Stephen Carbone, declare and s tate:1 .y name is Stephen C arbone. I am a De fendant in this lawsuit. I am cap able ofmaking this Declaration. I have read the a t tached answ ers to Plaintiff NZK Production Inc. 'sFirst Set of Special Interrogatories, and every statement contained therein is within my personalknowled ge and is true and correc t.I declare under pena lty of perjury of the laws of the United States of Am erica that theabove facts are true and correct , and that this Declaration was executed this -74 day of March ,

2012 in Dallas, Texas.

Stepl en Crbne

DECLARATION OF STEPHEN CARBONE-2- Exhibit E

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PROOF OF SERVICE2

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STATE OF TEXAS, COUNTY OF DALLAS3 At the time of service, I was over 1 8 years of age and not a party to this action. I amemployed in the County of Dallas, State of Texas. My business address is 8226 DouglasAvenue, Suite 411, Dallas, Texas 75225

On M arch 9, 2012 I served a true copy of the foregoing document described asDEFENDANT STEPHEN CARBONE'S RESPONSES TO PLAINTIFF NZKPRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIESon the interest parties in this action as follows:

Michael J. O'Conner, EsqAndrew W . DeFrancis, EsqKELLEY DRYE & WARREN LLP1010 0 S anta Monica Boulevard, Twenty-Third FloorLos Angeles, CA 900 67-4008Tel: (310)712-6100Fax: (310) [email protected]@kelleydrye.com

Attorneys for Plaintiff NZK Productions, Inc. aCalifornia Corporation and Horizon AlternativeTelevision, Inc., a Delaware CorporationBY UNITED STATE POSTAL SERVICE: I enclosed a said document in an envelopeor package and addressed to the persons at the addresses listed in the Service List. I placed theenvelope or package for collection at an office or regularly utilized drop bo x of Un ited StatesPostal Service or delivered such docum ent to a courier or driver authorized by the United StatesPostal Service.

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FED ERA L: I declared under penalty of perjury under the laws of the United States ofAm erica that the foregoing is true and correct and that I am a m ember of the State Bar of Texasand have been admitted to practice before this court Pro Hac Vice.Executed on March 9, 2012, at Dallas, Texas.

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EXHIBIT FTO


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Gregg A. Farley, SBN 115593LAW OFFICES OF GREGG A . FARLEY11755 W ilshire Blvd., Ste. 1845Los Angeles, CA 90025Telephone: (310) 445-4024Facsimile: (310) 445 [email protected]. Bradley K izzia (Pro Hac Vice)BROW N FOX KIZZIA & JOHNSON PLLC8226 Dou glas Avenue, Suite 411Dallas, Texas 75225Telephone: (469) 893-9940Facsimile: (214) 613 [email protected] for DefendantsSTEPHEN CARBONEand REALITY STEVE, LLC


NZK PRODUCTIONS INC., aCalifornia corporation, and HORIZON )ALTERNATIVE TELEVISION INC., a)Delaware corporation,)Plaintiffs,VS.STEPHEN CARBONE, an individual,and REALITY STEVE, LLC, a Texaslimited liability corporation,

Case No.: CV11-10118-GHK (Ex)

DEFENDANT REALITY STEVE,LLC'S RESPONSES TO PLAINTIFFNZK PRODUCTIONS INC.'S FIRSTSET OF SPECIALINTERROGATORIES

Defendants. Exhibit F- 1 -age 49REALITY STEVE, LLC'S RESPONSES TO


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PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC.RESPONDING PARTY:EFENDA NT REALITY STEVE, LLCSET NO.:NE

Exhibit FPage 50

REALITY STEVE, LLC'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES

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TO: THE PARTIES AND TO THEIR ATTORNEYS OF RECORD:

SPECIAL INTERRO GATO RY NO. 1:IDENTIFY each PERSON with whom YOU registered

www.realitysteve.com between January 1, 2004, and the present.The term "IDENTIFY ," as used in these Interrogatories, shall mean: (a) as to

an individual, stating his or her full and customarily used names, present resident

address, business address, and business telephone number; (b) as to any personother than an individual, stating its legal name and any other names used by it, theform or manner of its organization (e.g., partnership, corporation, etc.), the state ofits incorporation (if it is incorporated) or the state of its formation (if it is apartnership or limited liability company), and the address of its principal place ofbusiness; (c) as to any document, its author, recipient, sender, date(s), its subjectmatter, the number of pages therein, and wherever possible its correspondingBATES number(s); and (d) as to an event, transaction, or occurrence stating itsdate, the location and the manner of its occurrence (e.g., face-to-face meeting ofparticipants, telephone calls, etc.), the identification of all its participants andeyewitnesses to its occurrence, its purpose and subject matter, a concise descriptionof what transpired, and IDENTIFY any document referring to or concerning saidevent, transaction, or occurrence. Exhibit F

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The terms "PERSON" and "PERSONS," as used in these Interrogatories,shall mean all natural persons, partnerships, consortia, joint ventures, and everyother form o f legally recognized entity, including corporations.

The terms "YOU," "YOUR," or " DEFENDANT," as used in theseInterrogatories, shall mean Defendant Reality Steve, LLC and each of its past andpresent agents, associates, managers, representatives, accountants, attorneys, andanyone else acting, or who has acted, on its behalf, including Defendant Stephen

Carbone.ANSWER:

www.realitysteve.com has only been registered with Stephen Carbone sinceJanuary 1, 2004.SPECIAL INTERROG ATORY NO . 2:

State the date(s) YOU registered www.realitysteve.com with each of thePERSONS identified in response to Special Interrogatory No. 1.ANSWER:

The website was registered with Stephen Carbone on or around January 1,2004.SPECIAL INTERROG ATORY NO . 3:

IDENTIFY each PERSON who HOSTED www.realitysteve.com betweenJanuary 1, 2004, and the present.xhibit F-4-age 52REALITY STEVE, LLC'S RESPONSES TONZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIESCase 2:11-cv-10118-GHK-E Document 29-1 Filed 03/26/12 Page 55 of 74 Page ID #:285


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The term "HOSTED," as used in these Interrogatories, shall mean the act ofproviding server space, internet services, and/or file maintenance for w ebsites.A N SWER :

Yahoo Small Business and StormDemand.com have hostedwww.realitysteve.com between January 1, 2004 and the present.SPECIAL INTERROGA TORY N O. 4:

State the date(s) that each PERSON identified in response to SpecialInterrogatory N O. 3 HOS TED ww w.realitysteve.com .A N SWER :

Yahoo Small Business hosted the website until January 26, 2010.www.StormonDemand.com has hosted the website from January 26, 2010 throughthe present.SPECIAL INTERROGA TORY N O. 5:

IDENTIFY all agreements of any kind entered into between January 1,2004, and the present concerning advertising on www.realitysteve.com .A N SWER :

Defendant objects to this Special Interrogatory on the grounds that it isoverly broad, vague and unduly burdensome. Subject to the foregoing objectionsand without waiving same, Reality Steve has entered into agreements with thefollowing companies concerning advertising on the website: Google Adsense,

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Value Click, Lijit, CPMonly, Underground Media, Adtegrity, Vibrant, andGunggo.SPECIAL INTERRO GATOR Y NO. 6:

IDENTIFY all PERSONS who have purchased advertising onwww.realitysteve.com between January 1 , 2004, and the present.ANSWER:

There have been a small number of independent advertisers that havepurchased advertising on the website. The advertising purchased was only for atwo-week period, and none of the advertisers were in California.SPECIAL INTERROGATORY NO 7:

State all usemame accounts registered on www.realitysteve.com .ANSWER:

Defendant objects to this Special Interrogatory on the grounds that it isunduly burdensome and not calculated to lead to the discovery of admissibleevidence. Subject to the foregoing and without waiving same, Defendant respondsas follows: there are approximately 17,000 users on www.realityseve.com , andeach user has logged onto the w ebsite and crated a username at some p oint in time.SPECIAL INTERROG ATORY N O. 8:

For each of the usemame accounts identified in response to SpecialInterrogatory No. 7, state the email address affiliated with each account.

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ANSWER:Defendant objects to this Special Interrogatory on the grounds that it is

unduly burdensome and not calculated to lead to the discovery of admissibleevidence. Subject to the foregoing and without waiving same, Defendant respondsas follows: there are approximately 17,000 users on www.realityseve.com , andeach user has logged onto the website and crated a username at some point in time.The email addresses do not reflect the user's state of residence.SPECIAL INTERROGATORY NO. 9:

IDENT IFY all PERS ONS who have a contractual relationship of any kindwith www.realitysteve.com .ANSWER:

Yea! Networks, LLC220 E. Las Colinas BoulevardSuite C120Irving, Texas 75039Steve CookKris Drouet25502 Coral Wo od StreetLake Forest, California 92630

SPECIAL INTERROGATORY NO. 10:Describe YOUR contractual relationship with each PERSON identified in

response to Special Interrogatory No. 9.Exhibit F

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ANSWER:Yea! Networks, LLC is a five percent (5%) owner of Reality Steve, LLC.

3 Steve Cook is the manager of the Cooking Group, and was receiving a commissionfrom www.realitysteve.com . Reality Steve's contractual relationship with SteveCook ceased on February 15, 2012. Kris Drouet is an independent contractor who

7serves as Reality Steve's webmaster, and as such, receives a commission fromwww.realitysteve.com that is deposited in a bank account in Texas. The contract

1 0and the work that Mr. Drouet performs is done online and has nothing to do withhis residence. He could live and be anywhere in the world and do his work as an

13 independent contractor, as long as he has internet access.1 4

SPECIAL INTERROGATORY NO. 11:IDENTIFY all members of Reality Steve, LLC from January 1, 2004,

1 7through the present.ANSWER:

20 The members of Reality Steve, LLC have been, and currently are, Stephen21Carbone and Yea! Networks, LLC.SPECIAL INTERROGATORY NO. 12:

24 For each of the PERSONS identified in response to Special InterrogatoryNo. 1 1 , state the date(s) each PERSO N w as a member of Reality Steve, LLC.

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ANSWER:Stephen Carbone became a member of Reality Steve, LLC on July 11, 2011.

Yea! Networks, LLC became a member of Reality Steve, LLC on August 17,2011.SPECIAL INTERROGA TORY NO . 13:

State the monthly number of visitors to www.realitysteve.com betweenJanuary 1, 200 4, and the present.ANSWER:

www .realitysteve.com has approximately 2,00 0,000 visitors per month.SPECIAL INTERROGATORY NO. 14:

State the monthly number of visits to www.realitysteve.com by PERSONSlocated in California between January 1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory on the grounds that it isunduly burdensome and not calculated to lead to the discovery of admissibleevidence. Subject to the foregoing and without waiving same, I do not know. Thewebsite has approximately 2,000,000 visitors per month, and the email addressesof the visitors do not indicate where the visitors live.

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SPECIAL INTERROGATORY N O. 15:State the monthly number of visits to www.realitysteve.com by computers

located in California between January 1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory on the grounds that it isunduly burdensome and not calculated to lead to the discovery of admissibleevidence. Subject to the foregoing and without waiving same, I do not know. The

email address of each person who visits the website does not indicate the locationof each person's computer.SPECIAL INTERROGATORY NO. 16:

IDENT IFY all bank accounts that YOU own or control in California.ANSWER:

Reality Steve, LLC does not own or control any bank accounts in California.SPECIAL INTERROGATORY NO. 17:

IDENTIFY all sources of income that YOU derive from California,including all income derived from PER SON S w ho reside in California.ANSWER:

Reality Steve, LLC does not derive any income from California..

Exhibit F-10-age 58


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SPECIAL INTERROGATORY NO. 18:IDENTIFY each time that YOU paid income taxes in California between

January 1, 2004, and the present.ANSWER:

Reality Steve, LLC has not paid any income taxes in California betweenJanuary 1, 2004 and the present.SPECIAL INTERROGATORY NO. 19:

IDENTIFY all trips to California made on behalf of YOU between January1, 2004, and the present.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad andunduly burdensome. Su bject to these objections and without waiving sam e, no tripshave been made to California on behalf of Reality Steve, LLC between January 1,2004 and the present.SPECIAL INTERROGATORY NO. 20:

Describe the purpose of each of the trips identified in response to SpecialInterrogatory N o. 19.

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ANSWER:Defendant objects to this Special Interrogatory because it is overbroad and

unduly burdensome. Subject to these objections and without waiving same, seeAnsw er to Special Interrogatory No . 19.SPECIAL INTERROGA TORY NO . 21:

IDENTIFY each PERSON from whom YOU received any informationconcerning THE BACHELOR SERIES between January 1, 2004, and the present.

The term "THE BACHELOR SERIES," as used in these Interrogatories,shall mean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad"television series.ANSWER:

Defendant objects to this Special Interrogatory because it is overbroad,unduly burdensome, and not reasonably limited in scope to information that isrelevant to Defendant's objection to jurisdiction in California. Defendant furtherobjects because as stated, the interrogatory seeks irrelevant information notreasonably calculated to lead to admissible evidence and information that isproprietary and subject to the journalistic privilege. Subject to these objections andwithout waiving same, I do not recall any names, dates or details of possiblecommunications with California residents years go, but I do not believe I have

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made or received any communications with residents of California about non-public information concerning the B achelor series since January 1, 20 11.SPECIAL INTERRO GATO RY NO . 22:

For each of the PERSONS identified in response to Special InterrogatoryNo

plaintiff's 1st set of interrogatories for reality steve llc & steve carbone

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