adam galvez sworn declaration riddled with lies

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Charles Rodrick, pro per

34522 North Scottsdale Road, #120-467

Scottsdale, AZ 85266

480-250-3838

[email protected]

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

Charles Rodrick, et al., ) Case No.: CV2013-003800

Plaintiffs )

v. )

) PLAINTIFF/COUNTERDEFENDANTS ) NOTICE OF USE OF APRIL 7, 2014,

David M. Ellis, et al., ) DEPOSITION OF ADAM GALVEZ,

Defendants ) AT TRIAL

_________________________________ )

)

David M. Ellis, et al.. )

Counterclaimants ) (Assigned to the Hon. Katherine Cooper)

)

v. ) )

Charles Rodrick, et al., )

Counterdefendants )

________________________________ )

)

and )

) David Michael Ellis and Margaret Ellis, ) Third-Party Plaintiffs ) ) v. ) ) Brent Oesterblad, et al., ) Third-Party Defendants) ____________________________________

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Plaintiff/counterdefendant Charles Rodrick, pro per, hereby provides Notice of

the use of the entire April 7, 2014, the Sworn Depositions of Adam Galvez at trial.

As undeniably shown in the entire April 7, 2014, Sworn Deposition of Adam

Galvez, Mr. Galvez has submitted testimony in stark contrast to his pervious perjurious

Sworn Depositions, which have already been submitted to this Court.

In addition, the April 7, 2014, Sworn Deposition will undeniably impeach

previous testimonies and all claims made by Mr. Galvez. [Exhibit 1].

Attached as Exhibit 1, is only one small example of the many lies and false

claims made by Adam Galvez.

Respectfully submitted this Sunday, April 13, 2014.

By: /s/ Charles Rodrick




480-250-3838

[email protected]

CERTIFICATE OF SERVICE

ORIGINAL of the foregoing electronically filed this Sunday, April 13, 2014, with:

Clerk of the Court

Maricopa County Superior Court

THE MARK LAW FIRM

14175 W. Indian School Road

Goodyear, Arizona 85395

Attorneys for Plaintiff/ Counterdefendant Traci Heisig

Rick Poster, Esq.

THE POSTER LAW FIRM, PLLC

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11024 North 28th Drive, Suite 200

Phoenix, Arizona 85029

Attorneys for Defendant/Counterclaimant/

Third Party Plaintiff David M. Ellis

Joe M. Romley, Esq.

JOE M. ROMLEY, P.C.

4518 North 32nd Street, Suite 100


Attorney for Defendant Lois Flynn

Randal L. Hutson, Esq.

THE RANDAL HUTSON LAW FIRM, PLLC

34975 North Valley Parkway, Suite 152


Attorneys for Defendant Susan and Adam Galvez

BRUNTROCK LAW GROUP, LLC

2158 N. Gilbert Rd., Suite 119

Mesa, AZ 85203

Attorneys for Third-Party LArgent

By: /s/ Charles Rodrick




480-250-3838

[email protected]

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Exhibit 1

MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF JOHN DOE #5

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Janice M. Bellucci, Esq., SBN 108911 LAW OFFICE OF JANICE M. BELLUCCI 235 East Clark Avenue, Suite C Santa Maria, California 93455 Tel: (805) 896-7854 Fax: (805) 349-8872 [email protected] Attorney for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

JOHN DOE #1, et al., Plaintiffs, vs. BRENT OESTERBLAD, et al., Defendants.

CASE NO. CV13-01300-PHX-SRB

MOTION TO WITHDRAW AS COUNSEL

HONORABLE SUSAN R. BOLTON

Janice M. Bellucci and the Law Office of Janice M. Bellucci hereby move for leave to

withdraw as counsel for John Doe #5, pursuant to LRCiv. 83.3(b)(3)(B). This motion is supported

by the attached Certificate of Counsel. This matter has been set for trial on March 10, 2015, and

there is good cause for the Court to permit attorney to withdraw. A form of order is provided.

Plaintiff John Doe #5 has been apprised of the undersigneds intent to withdraw and Plaintiff

John Doe #5 has been apprised of the status of the case including the date of trial. The name,

address and telephone number of Plaintiff John Doe #5 is not listed in accordance with the Courts

Order Granting Application for Leave to Proceed Under Pseudonym dated April 2, 2013.

. RESPECTFULLY SUBMITTED this 9th

day of April, 2014.

By: _____/S/_____________________ JANICE M. BELLUCCI

Attorney for Plaintiffs

Case 2:13-cv-01300-SRB Document 142 Filed 04/09/14 Page 1 of 5

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DECLARATION OF JANICE M. BELLUCCI

I, Janice M. Bellucci, hereby declare as follows:

1. John Doe #5 signed a retainer agreement with attorney Janice M. Bellucci on

November 30, 2012. That agreement includes the following provision: Client shall be truthful and

cooperate in all respects with Attorney. See Exhibit A1.

2. Subsequent to signing the retainer agreement, John Doe #5 communicated to me via

telephone that he was not required to register as a sex offender and had never been required to

register as a sex offender.

3. I am the attorney of record for John Doe #5 in the United States District Court for the

Central District of California Case No. EDCV13-514-JGB.

4. In the capacity of attorney of record for that case, I drafted an original complaint for

relief which was provided to John Doe #5. The draft complaint included the statement that John

Doe #5 was convicted of a sex-related offense in 1996 in the State of Washington but is not

required to register as a sex offender.

5. John Doe #5 reviewed the draft complaint but did not request that the above

statement be revised or removed. John Doe #5 verified the complaint on March 18, 2013. See

Exhibit B.

6. The original verified complaint, which included the statement that John Doe was

convicted of a sex-related offense in 1996 in the State of Washington but is not required to register

as a sex offender, was filed on March 20, 20132.

7. As attorney of record in that case, I drafted an amended complaint for relief which

was provided to John Doe #5. The draft amended complaint included the statement that John Doe

#5 was convicted of a sex-related offense in 1996 in the State of Washington but is not required to


1 In accordance with Courts Order Granting Application for Leave to Proceed Under Pseudonym

dated April 2, 2013, Plaintiffs will request that all exhibits to this certificate be sealed in order to protect the true identity of John Doe #5. 2 See Docket #1, page 4, lines 12-14.


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8. John Doe #5 reviewed the draft amended complaint but did not request that the above

statement be amended or removed. John Doe #5 verified the amended complaint on April 9, 2013.

In that verification, John Doe #5 stated, I have read the foregoing Amended Complaint for Relief.

The facts stated therein are true of my own knowledge, except to matter that are therein stated on

my own information and belief, and as those matters I believe them to be true. John Doe #5 signed

the verification of amended complaint under penalty of perjury. See Exhibit C.

9. The amended and verified complaint, which included the statement that John Doe

was convicted of a sex-related offense in 1996 in the State of Washington but is not required to

register as a sex offender, was filed on April 10, 20133.

10. I prepared a draft declaration for John Doe #5 in support of an ex parte application

for a temporary restraining order (TRO). The draft declaration included the statement, I am not

required to register as a sex offender nor have I ever been required to register as a sex offender.

11. John Doe #5 reviewed the draft declaration, but did not request any changes to the

above statement in that declaration. John Doe #5 signed the declaration on April 24, 2013. See

Exhibit D4. The declaration of John Doe #5 supported Plaintiffs Application for Temporary

Restraining Order which was filed on April 26, 20135.

12. The United States District Court for the Central District of California Case No.

EDCV13-514-JGB was transferred to the United States District Court of Arizona and was assigned

therein as Case No.: 2:13-CV-01300-SRB6.

13. Subsequent to the transfer of the case to the United States District Court of Arizona,

John Doe #5 signed a revised retainer agreement on August 14, 2013, which states in relevant part

that Client shall be truthful and cooperate in all respects with Attorneys. See Exhibit E.

14. John Doe #5 was deposed by Defendant on April 7, 2014. During that deposition,

John Doe #5 testified that he is currently required to register as a sex offender due to his conviction

3 See Docket #15, page 4, lines 11-14.

4 Exhibit E was filed on April 2, 2013, and is Docket #13.

5 See Docket #19

6 See Docket #62 dated June 28, 2013


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for a sex offense in 1996. John Doe #5 also testified during the deposition that he has been required

to register as a sex offender at all times relevant to this case.

15. I notified John Doe #5 via telephone on April 8, 2014, of my intent to withdraw as

counsel due to his failure to be truthful and cooperate in all respects with attorney.

16. I provided John Doe #5 via E-mail on April 9, 2014, with a copy of the Courts

scheduling order dated January 27, 2014, which established March 10, 2015, as the date of trial for

this case.

17. The trial date of March 10, 2015, is approximately 11 months later than this Motion

to Withdraw as Counsel and therefore John Doe #5 has sufficient time to retain a substitute attorney

to represent him in this case.

I declare under penalty of perjury that the foregoing is true and correct.

RESPECTFULLY SUBMITTED this 9th

day of April, 2014.

By: _____/S/_____________________ JANICE M. BELLUCCI

Attorney for Plaintiffs


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CERTIFICATE OF SERVICE

I, the undersigned, certify and declare that I am over the age of 18; I am a resident of the

County of San Luis Obispo, State of California, and not a party to the above-entitled cause. I also

hereby certify that, on the same date set forth above, I electronically transmitted the foregoing

document to the Clerks Office using CM/ECF System for filing and to Defendant Chuck Rodrick

by U.S. first class mail and electronic mail:

Chuck Rodrick 34522 N. Scottsdale, #120-467 Scottsdale, AZ 85266 Defendant pro se

I hereby certify that, on the same date, I served the attached/foregoing document to Plaintiff

John Doe #5 by U.S. first class mail and electronic mail. The address for Plaintiff John Doe #5 is

not listed below in accordance with the Courts Order Granting Application for Leave to Proceed

Under Pseudonym dated April 2, 2013.

I hereby certify that, on the same date, I served the attached/foregoing document to Plaintiff

Pro Se John Doe #7 by electronic mail. The email address for Plaintiff Pro Se John Doe #7 is not

listed below in accordance with the Courts Order Granting Application for Leave to Proceed Under

Pseudonym dated April 2, 2013.

I declare under penalty of perjury under the laws of the State of California that the foregoing

is true and correct.

Dated: April 9, 2014 _________________________

Mamie Page


MamieMy Signature

ORDER GRANTING WITHDRAWAL AS COUNSEL

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Janice M. Bellucci, Esq., SBN 108911 LAW OFFICE OF JANICE M. BELLUCCI 235 East Clark Avenue, Suite C Santa Maria, California 93455 Tel: (805) 896-7854 Fax: (805) 349-8872 [email protected] Attorney for Plaintiffs


DISTRICT OF ARIZONA


CASE NO. CV13-01300-PHX-SRB [PROPOSED] ORDER GRANTING

MOTION TO WITHDRAW AS COUNSEL

HONORABLE SUSAN R. BOLTON

The Court, having received and considered the Motion to Withdraw as Counsel and good

cause appearing therefor,

IT IS HEREBY ORDERED granting the withdrawal of the Law Offices of Janice M.

Bellucci and Janice M. Bellucci as attorney of record for John Doe #5.

Dated this __ day of April, 2014.

__________________________ Susan R. Bolton United States District Judge

Case 2:13-cv-01300-SRB Document 142-1 Filed 04/09/14 Page 1 of 1

LODGED/FILED UNDER SEAL

EXHIBITS A THROUGH E TO MOTION TO WITHDRAW

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Janice M. Bellucci, Esq., SBN 108911 LAW OFFICE OF JANICE M. BELLUCCI 235 East Clark Avenue, Suite C Santa Maria, California 93455 Tel: (805) 896-7854 Fax: (805) 928-8736 [email protected] Attorney for Plaintiffs John Doe #1, John Doe #2, John Doe #3, John Doe #4, John Doe #5, John Doe #6, John Doe #7, John Doe #8, Jane Doe #9, and Jane Doe #10


DISTRICT OF ARIZONA


Case No.: CV-13-01300-PHX-SRB LODGED: PROPOSED EXHIBITS

A THROUGH E TO MOTION TO

WITHDRAW AS COUNSEL

HON. SUSAN R. BOLTON



MamieTextboxEXHIBIT A


MamieTextboxEXHIBIT B


MamieTextboxEXHIBIT C


MamieTextboxEXHIBIT D


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')A ..;.. '+

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I, Adam Galvez, hereby declare as follows:

1. My name is Adam Galvez and I am Plaintiff John Doe #5 in the above captioned

e-ase. .

2. I am a citizen of the United States and a resident of the City of Seattle, State of

Washington, and have been at all times relevant to this action.

3.

4. I am not required to register as a sex offender nor have I ever been required to


:'5 . Tnformation regarding me, including my name, photograph, personal information and

identification as a sex offender has been publicly posted on privately owned websites, including, but

not limited to, SORarchives, Offendex and Online Detective, at all times herein mentioned and

rele\,.ant to ttlis action.

6. I did not and have not provided the websites listed above with consent for the posting

of information regarding myself, including, but not limited to, my name, photograph, personal

infom1ation or identification as a registered sex offender_

7. On or about August 2012, I requested removal of my name, photograph and other

personal information from the privately owned websites listed above. The websites demanded

r:ayn1ent in the an1011nt c~f $500 in t;rder to ren1C1\le that inforn1aticn1 frorn the \Vebsltes.

8. Because I did not pay the demanded amounts, publication of my name, photograph

and other personal information on the privately owned websites listed above continues. In addition,

tl1e \vebsites listed ab:J\'e h.a\re added details regardi11g I11Jt sex ... related offe11se to the \vebsites.

9. The websites listed above have also added the names, photographs, and personal

information regarding my mother, Susan Galvez, and my brother, Brian Galvez. The information

regarding n1y n1t)ther and l1rc;tl1er CHi the 1vvel1sites listed alxrve \-Va5i linked tf; infc~rrnatitJn regarding me.

2 DECLARATION OF ADAM GALVEZ IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING

ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION

11---------------

Pavilion SleeekbookHighlight



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ATTORNEY RETAINER AGREEMENT

This Agreement dated as of the _____ day of August, 2013, in the City of Santa Maria, County

of Santa Barbara, California.

BETWEEN:

Janice Bellucci (Licensed in California) and Frankie Adamo (Licensed in Arizona) (Attorneys)

and Adam Galvez

(Client)

1. Conditions

This Agreement will take effect on the date stated above.

2. Scope and Duties

a. Client hires Attorneys to represent him for the purpose of suing in the United States District Court for the District of Arizona the owners, operators, and maintainers of three websites: Offendex, SORarchives, Online Detective, which includes any other website(s) where Defendant(s) have an interest or presence that maintains a list wrongfully showing Client as a registered sex offender (RSO) as well as Client's personal information, such as photos, home addresses, age, gender, hair color, eye color and date of birth, associated with client and/or his/her family members.

b. Attorneys shall represent Client in only the matter mentioned above and

reserves the right to accept or decline representation of additional parties not expressly stated herein. Attorneys do not represent Client in any other claims, disputes, or proceedings, even if related to the Matter unless Attorneys enter into a separate written agreement with Client. Attorneys shall take all reasonable steps to keep Client informed of progress and to respond to Clients inquiries.

c. Client shall be truthful and cooperate in all respects with Attorneys and keep

Attorneys informed of all developments with respect to the foregoing, including any change in Clients address, telephone numbers and/or whereabouts. Client agrees to abide by this Agreement.

d. Client agrees to cease all communication with all third parties, including but

not limited to, the media regarding the subject matter of this claims. 3. Retainer/Advance Deposit of Fees

Client is not required to pay a retainer or an advanced fee deposit.


MamieTextboxEXHIBIT E

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4. Legal Fees

Attorneys fees and costs are not set by law but are negotiable between Attorneys and Client. Attorneys have agreed to handle this case on a contingency-fee basis, with the full amount of fees deferred in the event of a fee award or other form of fee recovery, such as a settlement. Therefore in this matter Client will not be required to pay any Attorneys fees unless Client receives an award or settlement, fees are paid by a third party, or otherwise awarded or paid on Client's behalf. Under such circumstances, Attorneys will receive an interest in said fees, as explained below.

a. Twenty-five (25) percent of the gross amount recovered by settlement prior to the filing of a complaint; _______ Client Initials

b. Thirty-three and a third (33 1/3) percent of the gross amount recovered by

settlement after a complaint is filed, but before a trial or arbitration hearing is commenced; _______ Client Initials

c. Thirty-five (35) percent of the gross amount recovered during or

immediately following an arbitration hearing by award, settlement, or otherwise; _______ Client Initials

d. Forty (40) percent of the gross amount recovered, by award, settlement, or

otherwise, during or immediately after the first trial or commencement of an appeal by any party of an arbitration decision; or _______ Client Initials

e. Forty-five (45) percent of the gross amount recovered by award, settlement,

or otherwise, if an appeal or further action is taken after the first trial. ________ Client Initials

In the event of any appeal, Client agrees that he/she is responsible for payment of the appeal bond(s) to the Court, and that Attorneys reserve the right to charge a fee that is the greater of the aforesaid contingency fees or Attorneys customary hourly rate per hour as stated herein. Moreover, upon termination of either Attorney as herein stated, said Attorney shall be entitled to an attorneys fee for all time spent on behalf of the Client. Client understands that the Attorneys customary hourly fee for handling non-contingent matters is provided herein and that the attorneys fee sought by the Attorney will be based upon the Attorneys customary fee multiplied by 1.5 due to the contingent nature of this fee agreement. _______ Client Initials

For example, if the case settles for $100.00 prior to the filing of a complaint and

there are no costs, we receive $25.00 and you receive $75.00. If the case settles for $100.00 after the filing of a complaint and you owe $20.00 in costs, we receive $33.34 for attorneys' fees and $20.00 for costs and you receive $36.66.

As provided herein, our fees will be payable only out of amounts recovered. If no

recovery is obtained, no fees will be payable to us. However, you will remain liable for all costs incurred on your behalf regardless of recovery.


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Attorneys will pay all costs necessary in the administration and prosecution of the aforesaid matter, including but not limited to court costs such as filing fees, transcript costs, copies of pleadings; and out-of-pocket costs such as travel, postage, copying and facsimile transmission, experts, consultants and other contractor services. Costs may be advanced by third parties. All costs advanced shall be billed at the actual incurred cost or rate paid, without any markup for overhead, and collected from the net amount recovered, after Attorneys fees, from any award, settlement, or otherwise paid. Any cost not authorized by law or in violation of either the California or Arizona Rules of Professional Conduct and Ethics are hereby excluded.

a. Assignment of Attorneys Fees

If your case is successful, the court may require that some or all of the costs and attorneys fees be paid by the opponents. Therefore, Attorneys make a claim for all fees and costs incurred from the opponents or such fees that may be paid as part of a settlement or by a third party. Attorneys believe and have advised Client that such recovery in unlikely in this matter.

Nevertheless, Client hereby agrees to assign any fees and costs received by any means listed above to Attorneys. This assignment is binding upon Client as well as Clients agents and legal successors. If no amount or an inadequate amount of fees and costs are received by Client, Client also assigns to Attorneys all right, title and interest Client may have to recovery of any monetary damages by way of an legal claim, counterclaim, or cross-claim against anyone, related to the matter, up to and including the full amount of any fees (pursuant to the hourly rates below), costs, and other expenses incurred by Attorneys that are not fully reimbursed from other sources. You also agree to act in good faith in order not to impair, impede, delay or waive in whole or in part any entitlement to recovery or attorneys fees.

b. Determination and Distribution of Fees and other Funds

Client understands and agrees to a fee-sharing arrangement under which Attorneys will receive attorneys fees based upon a percentage determined by the total number of hours spent on the case. This is called the lodestar amount.

For purposes of fee awards, reimbursements, settlements, and other relevant situations, the customary hourly rates of Attorneys as of the date of this agreement are $395 (Bellucci) and $250 (Adamo).

5. Offers of Judgment

Client understands that an offer of judgment under Federal Rules of Civil Procedure 68 may be made to Client by Clients opponents at some point in the litigation and have discussed what this means with Attorneys. In the event Attorneys recommend that Client accepts the offer of judgment, and Client nevertheless rejects it, Client understands that (1) Attorneys retain the right to withdraw from the Matter (subject to court approval) and (2) if Attorneys continues to represent Client under such circumstances, Attorneys are under no obligation to pay such opponent costs (including attorneys fees) which the court may ultimately order Client to pay.


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6. Fee Claims By Defendants If Clients case is not successful, or if the court rules that the case is frivolous,

unreasonable or groundless, the court may order Client to pay the opponents costs and/or attorneys fees. In the event of such a court order, Client agrees to pay the entire amount of the opponents fees and costs awarded.

7. Termination Client and Attorneys retain the right to terminate this agreement for any lawful

reason, after giving reasonable written notice, and court approval if required. This includes but is not limited to:

The case becomes frivolous, unreasonable or groundless; An inability to reach agreement about strategy decisions; Representation of Clients interests requires taking an anti-civil rights position; A breakdown in the trust and cooperation needed for a successful

attorney/client relationship; The facts of Clients case are materially and significantly different than Client has

stated; Client rejects and offer of judgment after Attorney recommends its acceptance; Client fails to cooperate in all respects with Attorneys and keep Attorneys

informed of all developments with respect to the foregoing, including any change in Clients address, telephone numbers and/or whereabouts.

Client does not keep in communication with Attorneys.

Attorney(s) will follow the applicable Rules of Professional Conduct in withdrawing from representing Client, but is under no obligation to find a replacement lawyer to continue to represent Client.

Termination by Parties or any of them shall not affect, waive, or diminish Attorneys rights to collect any reimbursement for costs paid or for attorneys fees from any source referenced above. Whether done by Client or by Attorney, any termination of this agreement shall in no way terminate any obligation or duty incurred by Client prior to notice of such termination. Attorneys shall have no obligation to retain Clients files beyond one (1) year after the date of conclusion of Attorneys services hereunder.

8. No Guarantee As To Result and Disclaimer Legal disputes are, by nature, unpredictable. Attorneys make no representation,

guarantees or promises as to the result or probable outcome, the response of any opposing parties or the amount of or type of recovery, if any, that may be awarded, for the claims or the decision of any court.

NOTHING CONTAINED IN THIS AGREEMENT AND NOTHING IN ATTORNEYS STATEMENTS TO CLIENT SHALL BE CONSTRUED AS A PROMISE OR GUARANTEE ABOUT THE OUTCOME OF CLIENTS MATTER. ATTORNEYS MAKE NO SUCH PROMISES OR


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GUARANTEES. ANY COMMENTS BY ATTORNEYS ABOUT THE OUTCOME OF CLIENTS MATTER ARE EXPRESSIONS OF OPINION ONLY.

9. Lien Client herby grants Attorneys a lien on any and all monies due Client, claims or

causes of action which are the subject of Attorneys representation under this Agreement. Attorneys lien will be for any sums due and owing to Attorneys at the conclusion of Attorneys services. The lien will attach to any recovery Client may obtain, whether by arbitration award, judgment, settlement, or otherwise. Said recovery shall be deposited into a trust account whereupon Attorneys shall deduct any sums due to Attorneys by Client, and shall then pay the balance to Client.

10. Conflict of Interest

We are representing you and others in the same or a related matter. At this time, such representation is permitted because there does not appear to be a conflict of interest between the parties. This may change and a conflict may arise at some later point in the representation. We will continue to evaluate the case and the existence of any possible conflicts of interest. Should a conflict arise, we will advise all affected clients and comply with the applicable ethical rules which may include withdrawal.

Whenever Attorneys represent two or more parties at the same time with respect to the same matter, Attorneys are obligated to advise all such parties that there is a potential for conflict of interest. Such a conflict might arise, for example, if Attorneys act on behalf of both the buyer and seller in a purchase and sale transaction.

Notwithstanding such joint representation and any actual or potential conflict of interest, Client hereby consents to Attorneys joint representation providing Attorney discloses same beforehand. Furthermore, Client acknowledges and agrees that at no time will Attorneys representation be construed, claimed or deemed to be a breach of a fiduciary relationship, a conflict of interest or a violation of any other obligation to Client. Client agrees that at no time shall Client claim or contend that Attorney should be disqualified from representing any client in connection with any matter, related or unrelated.

11. Arbitration If any dispute arises between Client and Attorneys, the dispute shall be resolved by

binding arbitration in before a single arbitrator selected in accordance with those rules or the rules of any local Bar Association which is operating under the auspices of a State Bar or, if none, in accordance with the prevailing rules of the American Arbitration Association. The arbitrator shall have the discretion to order that the cost of arbitration, including arbitrators fees, or other costs, and reasonable attorneys fees, shall be borne by the losing party.


Notice of Use of April 7, 2014 Deposition of Adam GalvezExhibit 1 - Notice of Use of Depositon at TrialMotion to Withdraw - Adamjanice1Adam_Fed_Case_False_Claims

adam galvez sworn declaration riddled with lies

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