SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF...

Darren Mitchell Meade

(800) 993-4464U.S. LEGAL SUPPORT

172

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE

ARTHUR SCOTT CONNELLY, an individual, dba Body Rx, Plaintiff(s), vs. CASE NO. 30-2011-00453171

DOES 1 through 25, inclusive,

Defendant(s). _____________________________

DEPOSITION OF DARREN MITCHELL MEADE

VOLUME II

September 26, 2011

10:16 a.m.

1999 Avenue of the Stars, Suite 1000

Los Angeles, California

REPORTED BY:

Terrie C. Barker

CSR No. 12000



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1 APPEARANCES:

2

3 For Plaintiff(s):

4 MILLER BARONDESS, LLP ERIK S. SYVERSON

5 1999 Avenue of the Stars Suite 1000

6 Los Angeles, California 90067 310.552.5236

7 310.823.3997 Fax [email protected]

8

9 Also Present:

10 ARTHUR SCOTT CONNELLY

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1 INDEX TO EXAMINATION

2

3 WITNESS: DARREN MITCHELL MEADE, VOLUME II

4 EXAMINATION PAGE

5 By Mr. Syverson 177

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1 INDEX TO EXHIBITS

2 DARREN MITCHELL MEADE, VOLUME II

3 Connelly vs. Does 1 through 25

4 Monday, September 26, 2011

5 Terrie C. Barker CSR. No. 12000

6

7 MARKED DESCRIPTION PAGE

8 Exhibit FF E-mail string dated 6/18/10 178

9 Exhibit GG E-mail string dated 6/20/11 179

10 Exhibit HH E-mail string dated 7/21/10 183

11 Exhibit II E-mail dated 7/22/10 184

12 Exhibit JJ E-mail dated 7/22/10 188

13 Exhibit KK E-mail dated 7/25/10 192

14 Exhibit LL E-mail dated 7/25/10 194

15 Exhibit MM E-mail dated 7/27/10 199

16 Exhibit NN E-mail dated 8/6/10 200

17 Exhibit OO E-mail dated 8/17/10 204

18 Exhibit PP E-mail dated 9/16/10 209

19 Exhibit QQ E-mail dated 9/24/10 210

20 Exhibit RR E-mail dated 10/3/10 211

21 Exhibit SS E-mail dated 10/5/10 212

22 Exhibit TT E-mail string dated 12/7/10 213

23 Exhibit UU E-mail dated 12/11/10 215

24 Exhibit VV E-mail dated 1/7/11 217

25 Exhibit WW E-mail dated 1/19/11 219



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1 INDEX TO EXHIBITS (Continued)

2

3 MARKED DESCRIPTION PAGE

4 Exhibit XX E-mail string dated 6/20/11 221

5 Exhibit YY E-mail string dated 6/20/11 225

6 Exhibit ZZ E-mail dated 6/20/11 228

7 Exhibit AAA E-mail dated 9/26/10 231

8 Exhibit BBB E-mail dated 9/26/10 233

9 Exhibit CCC E-mail dated 9/24/10 234

10 Exhibit DDD E-mail dated 9/10/10 237

11 Exhibit EEE E-mail dated 9/10/10 238

12 Exhibit FFF E-mail dated 9/10/10 240

13 Exhibit GGG E-mail dated 2/22/11 241

14 Exhibit HHH E-mail dated 12/10/10 246

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1 LOS ANGELES, CALIFORNIA;

2 MONDAY, SEPTEMBER 26, 2011; 10:16 A.M.

3

4 DARREN MITCHELL MEADE,

5 having been first duly sworn, was examined and

6 testified as follows:

7

8 EXAMINATION

9

10 BY MR. SYVERSON:

11 Q Good morning, Mr. Meade. As you know, my

12 name is Erik Syverson. I'm the attorney for the

13 plaintiff, Scott Connelly, in the lawsuit styled

14 Connelly vs. DOES.

15 This is a continuation of our deposition

16 back in June. This will be styled as Volume II of

17 your deposition.

18 Does that make sense?

19 A Yes.

20 Q Now, at our previous deposition session, I

21 provided you with some general ground rules for how

22 the deposition would be conducted. Do you need me to

23 provide you with a refresher of that?

24 A No.

25 Q Okay. Is there any reason whatsoever that



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1 you cannot provide me with your best testimony here

2 today?

3 A The same as previously. I'm on a series of

4 heart medications which sometimes cause me to need to

5 refer to my notes.

6 Q Okay. Now, since our last time together in

7 June, have you changed any medications at all?

8 A No.

9 Q Same medications?

10 A Correct.

11 Q Okay. So we'll hop back into examining the

12 documents that you have produced pursuant to our

13 deposition notice. We are picking up with what will

14 be called Exhibit FF. And I will provide you with a

15 copy of that.

16 (Exhibit FF marked.)

17 BY MR. SYVERSON:

18 Q Now, take a minute to review this document

19 and familiarize yourself with it and let me know when

20 you're ready to speak about it.

21 A Okay. I reviewed it.

22 Q What is this document?

23 A This is a document from Adam Stuart

24 Zuckerman to myself updating me on Michael Brown and

25 Ken Barnes in regards to the lawsuit with



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1 Dr. Connelly.

2 MR. SYVERSON: We'll move on to what we will

3 style as Exhibit GG.

4 (Exhibit GG marked.)

5 THE WITNESS: I reviewed it, if you're

6 waiting on me.

7 BY MR. SYVERSON:

8 Q Okay. I'll start at the top. Now, this was

9 an e-mail forwarded from Darren Meade to

10 [email protected] on June 20, 2011; is that

11 correct?

12 A Correct.

13 Q So is this an e-mail or a string of e-mails

14 that you e-mailed to yourself?

15 A Yes.

16 Q And what was the purpose of that?

17 A This, I believe, was to have it ready for

18 this deposition.

19 Q I see. So your purpose in e-mailing it to

20 yourself was simply a document-gathering exercise; is

21 that correct?

22 A Correct.

23 Q So I'll leap down into the meat of it, an

24 e-mail from Ryan Page to Xvulture, and it looks like

25 you are cc'd on this, and the day is February 9,



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1 2011, 11:47 p.m.

2 Are you familiar with this paragraph or this

3 e-mail?

4 A Yes, I am.

5 Q You've reviewed it before?

6 A Yes.

7 Q And can you tell me what this paragraph is

8 referencing?

9 A This is Ryan Page writing to Adam Zuckerman

10 and I, talking about doing a defamation-type

11 article. The Drossman-style paper is a defamatory

12 article that was actually written about me. So it's

13 referencing that.

14 Ryan is suggesting a name here, "perhaps by

15 Jamie Redden." Renee Redden used to be somebody that

16 Dr. Connelly dated, so they're trying to work in that

17 reference.

18 And then they were talking about drafting a

19 new article calling Scott Connelly "Dr. Death,"

20 bringing in genocide, killing Vietnamese, and then,

21 you know, abortion to control population, and going

22 into steroidal compounds to kids, and how that would

23 create a new type of killer bar.

24 Q So you were copied on this. You understood

25 this as a discussion from Ryan to Adam. Who is -- I



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1 think you've already answered this, but for the

2 record, who is "Xvulture"?

3 A "Xvulture" is Adam Stuart Zuckerman.

4 Q And is "Stuart" Adam Zuckerman's middle

5 name?

6 A It is Adam's middle name; however, on many

7 of the [email protected], he utilizes his middle name

8 as his last name.

9 Q And you understood this to be a discussion

10 about producing false and defamatory content about my

11 client, Dr. Connelly?

12 A Correct.

13 Q Can I direct your attention to the content

14 below titled "Julia Drossman interview." And it

15 looks like you wrote a comment which says, "Yes, are

16 we doing a separate piece or will this be under the

17 guise of an interview with myself a la Julie

18 Drossman?"

19 What does that mean? Does that mean a fake

20 interview?

21 A It would be a similar piece to the one that

22 came out on myself. So if you referred to it, it

23 would be one that had hacked me for resume fraud. So

24 it is a false piece written with false facts.

25 Q I see. And that was the reference to "big



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1 Drossman-style paper" in the February 9 e-mail from

2 Ryan Page to Xvulture?

3 A Correct.

4 And then it was Ryan's goal to get something

5 up by Monday.

6 Q I see. And you're referencing page 2 of

7 this e-mail string?

8 A Yes.

9 Q I'd like to you direct your attention to the

10 bottom of page 2. This is a February 9th, 2011,

11 e-mail from Ryan Page to yourself at 6:26 p.m. And

12 Ryan Page -- and also [email protected] is copied on

13 this?

14 A Correct.

15 Q Do you remember receiving this e-mail?

16 A Yes, I do.

17 Q And what does this e-mail refer to?

18 A This e-mail is again from Ryan Page, that he

19 wanted to contribute to the defamatory piece and that

20 he saw a story line tying in, again, the Dr. Death,

21 which refers to Scott Connelly, into a scheme about

22 lying about -- well, the allegations that Scott lied

23 about his education and military experience, and

24 calling Scott Connelly a sociopath.

25 Q And the allegation that Connelly lied about



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1 his education, military experience, was that just

2 made up out of thin air? And if so, by who?

3 A The education section was in a newspaper

4 article that was in, I think, the "San Francisco

5 Examiner," so they were trying to reference that.

6 Q And what about the military experience?

7 A I have no idea about Scott's military

8 experience.

9 Q Do you know if this article that is being

10 discussed in this e-mail chain was ever -- was ever

11 authored?

12 A Yes.

13 Q And where was it published? Was it

14 published on the Internet?

15 A Yes, it was.

16 Q And do you know the domain name of where it

17 was published?

18 A Ascottconnelly.com.

19 Q Do you know the approximate date when it was

20 published?

21 A I would have to go back to look at the

22 website to see when the articles were posted.

23 MR. SYVERSON: Okay. Let's move on. We'll

24 style this as Exhibit HH.

25 (Exhibit HH marked.)



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1 BY MR. SYVERSON:

2 Q Let me know when you're ready to discuss

3 it.

4 A I'm ready to discuss it.

5 Q Okay. HH, we are looking at an e-mail from

6 [email protected], who you have stated is Adam Stuart

7 Zuckerman, to yourself on July 21st, 2010, and it

8 looks like a forwarded e-mail. And then Adam says to

9 you, "Power play."

10 Can you explain to me what this means?

11 A Yes. This was Adam letting me know that he

12 controlled the investor attorney for Venture Pharma,

13 which is Ken Barnes, and he had instructed Ken Barnes

14 to cancel out of the settlement meeting that was

15 scheduled with Dr. Connelly and his attorney, Sam

16 Krane, and Mark Fraser.

17 Q This will be Exhibit II.

18 Same as with all of these exhibits, please

19 take whatever time you need to review this and

20 familiarize yourself with it.

21 (Exhibit II marked.)

22 BY MR. SYVERSON:

23 Q This is an e-mail dated July 22nd from Adam

24 Zuckerman to Darren Meade.

25 A I've reviewed the document.



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1 Q And you are familiar with this document?

2 A Yes, I am.

3 Q And what is this document?

4 A This is a document from Adam Zuckerman that

5 he forwarded to me, and it's referencing that he's

6 going to cloak comments and make them look as if

7 they're coming from the investor group.

8 Q Can I stop you there? What -- let's take it

9 slow.

10 What does "cloak" these comments mean?

11 A With Adam Zuckerman, he constantly wanted to

12 cloak, which meant to hide his identity, because of

13 his criminal past.

14 Q What are the comments that he's referring

15 to?

16 A The comments he's referring to are in

17 regards to a patent which was for a universal

18 screw-top -- -top cap that would dispense protein

19 powder.

20 Q Okay. So he's talking about making comments

21 about his own product?

22 A He's talking about couching questions as if

23 they're coming from the investor group -- and the

24 investor group would be Venture Pharma or another

25 group called "Shared Success " -- and trying to make



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1 it look as if the investors were upset about a patent

2 that may have been available just for a company

3 called Progenex.

4 Q Why would the investors have been upset

5 about that?

6 A Adam, at this time, was stating that there

7 was a signed agreement that gave Progenex exclusive

8 rights to the Aquaflex cap, which was the universal

9 cap that I just mentioned.

10 Q Okay. So when Adam says to you, "This is a

11 good e-mail. Check the last line," what is he

12 referring to, or what did you understand him to be

13 referring to?

14 A I understood it to be referring that he

15 cloaks himself to actually be the investors, to

16 essentially threaten or rattle the saber of possible

17 litigation coming from the investors.

18 Q So when he says, "Check the last line," is

19 he referring to the last sentence in the e-mail from

20 Adam Stuart to "mindjunk" on July 5th, 2009, where

21 Adam states: "I'm currently finding more... and it

22 sickens me how much shit he's not been truthful

23 about"?

24 A I believe so.

25 Q Why was that last sentence important, as you



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1 understood it?

2 A At this time, I had been the CEO of Progenex

3 for a little over ten days, and they were trying to

4 portray, at this time, that the investors were being

5 taken advantage of by Scott Connelly.

6 So it's really part of my indoctrination

7 where they're trying to say that it was Scott

8 Connelly being untruthful, which I later found out to

9 be patently false.

10 Q What did Adam want to convince you that

11 Scott Connelly was being untruthful about?

12 A When I was recruited to come into this

13 company, I was told that there were investors that

14 had risked their life savings to invest into the

15 company and that Scott was starting a competing brand

16 called "Body Rx." So he was trying to just convey

17 through third-party sources that Scott had been

18 untruthful.

19 Q About starting a competing company?

20 A Starting a competing company; that he

21 defrauded investors who invested into the company.

22 And at this time, as I said, I had been CEO

23 for maybe ten days, and I was told that they had six

24 to eight weeks to turn the company around or they

25 would be insolvent.



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1 Q So Adam told you that Scott had misled

2 investors in Progenex or Body Rx?

3 A In Progenex.

4 Q Who's [email protected]?

5 A My understanding is that it's Ryan

6 HornBuckle.

7 Q And who is Ryan HornBuckle?

8 A I've never met Ryan HornBuckle. I'm told

9 that he was an associate of Vince Andrich.

10 Q Do you know why Adam Zuckerman is e-mailing

11 Ryan HornBuckle telling him that he is going to cloak

12 comments?

13 A No.

14 MR. SYVERSON: We are on JJ.

15 (Exhibit JJ marked.)

16 BY MR. SYVERSON:

17 Q This document is an e-mail from Adam

18 Zuckerman to yourself on July 22nd, 2010; is that

19 correct?

20 A Yes.

21 Q And what is this -- strike that.

22 Are you familiar with this document?

23 A Yes, I am.


25 A This is a document from Adam Zuckerman



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1 explaining how he was going to exert pressure on

2 Vince Andrich, who used to have an executive position

3 with Progenex.

4 Q Now, was there something attached to this

5 e-mail? I notice the attachment line references

6 "scottconnelly367(Vince Trash)."

7 Is that what -- is that what the following

8 pages are, starting with page 2 of this exhibit?

9 A Yes. It's, I believe, a Google chat between

10 Adam Zuckerman and Scott Connelly.

11 Q I see. And in looking at page 2 of this

12 exhibit, I notice there are icons. Do you know which

13 icon -- it looks like a penguin on the right-hand

14 side and a light bulb on the left. Do you know who

15 is who?

16 A Adam Zuckerman always utilized what he

17 called a vulture for his name, Xvulture. So the

18 penguin is actually a vulture which is Adam

19 Zuckerman. The light bulb is Scott Connelly.

20 Could I mention one issue on this exchange?

21 Q Sure.

22 A On the second page, if you go down it says,

23 "Yeah, I have Andrew making a bunch of contacts. He

24 can locate any target."

25 What I wanted to point out is that Andrew is



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1 Andrew Skylar Medal, who is another convicted felon,

2 although I didn't know it at the time.

3 When I was mentioning that Adam was taking

4 me through an indoctrination process, when he was

5 sending me this chat, which was supposed to be Scott

6 Connelly trashing Vince Andrich, he was also

7 indoctrinating me into what a good person Andrew was

8 and how he was valuable to the Progenex staff for a

9 low amount of money.

10 Q So as you understood it, that was the

11 purpose of attaching a chat between Adam Zuckerman

12 and Scott Connelly and providing it to you for your

13 review?

14 A Yes. It was twofold. One, it was to show

15 me that Scott was negative towards, you know, Vince

16 Andrich; and then secondly, to build up Andrew

17 Medal.

18 And I had later found out that there were

19 multiple convicted felons working out of Progenex.

20 Q Did you understand Andrew Medal to be

21 working out of Progenex at this time, July 22nd,

22 2010?

23 A Yes. And it's explained, actually, in this

24 chat that, you know, he was being paid $3,000 a

25 month.



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1 Q At that time, did you understand there to be

2 any problem or restriction from Andrew Medal working

3 at Progenex?

4 A No.

5 Q Have you subsequently discovered any

6 information that would indicate that that was a

7 problem or improper?

8 A Yes. He was remanded to Nevada High Desert

9 prison for working with Adam Zuckerman and Kirk

10 McMahon.

11 Q Anything else with regard to this document,

12 Exhibit JJ, that you feel is important?

13 A The only thing that I think is important

14 with this document is Scott Connelly is pointing out

15 very clearly about the flow of the marketing that was

16 needed as far as a messenger, the message, the

17 devotees, networks, and the sales.

18 The only reason I point that out is it

19 became apparent the longer I was the CEO that they

20 weren't looking to have a viable business. They

21 didn't know what they were doing and they failed to

22 execute.

23 MR. SYVERSON: We are on KK, a July 25,

24 2010, e-mail from Adam Zuckerman to Darren Meade, and

25 a number of parties are copied on this e-mail.



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1 (Exhibit KK marked.)

2 BY MR. SYVERSON:

3 Q Are you familiar with this document?

4 A Yes, I am.


6 A This is an e-mail that Adam Zuckerman sent

7 to myself, Lori Wildrick, Ryan Page, and Aaron

8 Thomas. Adam was creating a new website. The

9 website was going to be on something called "Body Rx

10 Pizza" and "WGFE." The reason why this is pertinent

11 is at the time, he wanted to make sure that if Scott

12 Connelly came out with Body Rx Pizza or tried to do a

13 new product that had Whey Growth Factor Extract in

14 it, that he could destroy it on the Internet with

15 derogatory websites.

16 The other people that are copied on this,

17 Lori Wildrick and Aaron Thomas, would be the primary

18 content writers and editors on any defamatory

19 articles that would come out.

20 Q As you understood it, Body Rx Pizza was a

21 product that Dr. Connelly was making or wanted to

22 bring to market?

23 A Yes. And there's a caveat to that, which is

24 Adam had showed me a contract which was an agreement

25 to negotiate in good faith. And in that,



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1 specifically, a product such as a pizza was called

2 out that was allowed to come out and be sold in the

3 marketplace.

4 This was Adam's e-mail, essentially showing

5 that he would circumvent that.

6 Q And he was going to post defamatory content

7 on the website or on the domain name

8 megalomaniac.com?

9 A Yes. And there was also going to be a WGFE

10 website and a Body Rx Pizza website. That's not

11 spelled out in this document, but there are

12 discussions that took place later in the year.

13 Q Okay. But this document is just referring

14 to megalomaniac.com?

15 A Correct.

16 Q But the idea remained the same, to post

17 defamatory content on this website?

18 A Correct.

19 Q Defamatory content about Dr. Connelly, I

20 should say?

21 A Defamatory content about Dr. Connelly.

22 There was also discussions later -- and I'm

23 not sure if I'm supposed to go into that -- but there

24 was a discussion that a settlement would occur. And

25 once the settlement occurred, there was going to be a



194

1 website called "Metrxman" that was going to come up

2 after the settlement.

3 Q After a settlement with who?

4 A After a settlement with Dr. Connelly.

5 Q Do you know if megalomaniac.com has any

6 content on it today?

7 A I don't know that.

8 Q Who do you understand to be the owner of

9 that domain name?

10 A The owner of that domain name is Adam

11 Zuckerman.

12 MR. SYVERSON: So we're on LL.

13 (Exhibit LL marked.)

14 BY MR. SYVERSON:

15 Q LL is a July 25th, 2010, e-mail from Adam

16 Zuckerman to yourself, Mr. Meade.


18 A Yes, I am.


20 A This is an e-mail from Adam Zuckerman to

21 myself mentioning www.metrxman.com.

22 Q And is that the domain you just referenced a

23 couple minutes ago?

24 A It's the domain I just referenced.

25 And just making a reference back to the



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1 previous exhibit which had Lori Wildrick copied on

2 it, I did read rough drafts of content that Lori

3 Wildrick had written for metrxman.com.

4 Q The idea -- you had mentioned metrxman.com a

5 couple minutes ago in discussing the megalomaniac.com

6 website. Was the idea similar with metrxman.com?

7 A It was similar, but this was the website

8 that was to come up after a settlement was made,

9 primarily because Adam Zuckerman is judgment-proof,

10 and the thought was that he would bring up a

11 defamatory website and there was nothing that Scott

12 Connelly could ever do legally.

13 Q I see. So megalomaniac.com, the idea was to

14 have it come up right away, whereas the idea of

15 metrxman.com was to not post any content on it until

16 there was a settlement?

17 A Until there was a settlement. Correct.

18 Q Do you know if any content did go up on

19 megalomaniac.com?

20 A I don't know on megalomaniac. I reviewed

21 some of the drafts in, probably, November on

22 metrxman.

23 Q Has anything gone up on metrxman yet?

24 A Not that I know of.

25 Q Adam Zuckerman told you his plan to post



196

1 defamatory content on metrxman.com after reaching a

2 settlement with Dr. Connelly?

3 A Correct.

4 Q What was his reasoning for that?

5 A The reasoning was specifically to make Scott

6 Connelly suffer and to not be able to pursue anything

7 in regards to his legacy in the sports nutrition

8 arena.

9 Q And how would that benefit Adam Zuckerman,

10 if he communicated that to you?

11 A Outside of just pure joy and to make

12 somebody suffer, I'm not sure what else the benefit

13 would be.

14 Q The expresser would be a benefit for

15 Progenex, that it would help them compete with Scott

16 Connelly's endeavors in the fitness marketplace?

17 A I believe I mentioned this in the first

18 depo. I'm not sure. So if I repeat myself, I

19 apologize.

20 Adam's goal or vision that he had is he felt

21 Scott was going to live maybe five to seven more

22 years, and what he wanted to do was to be able to

23 walk in to a hospital room when Scott would be on the

24 verge of death and be able to whisper into his ear,

25 "I stole your legacy, I stole your company, and now



197

1 I'm stealing your money" -- I'm sorry. It's the

2 reverse of those, "Steal your money, stole your

3 company, now I'm stealing your legacy."

4 Q You mentioned that Zuckerman was

5 judgment-proof. What do you mean by that?

6 A Adam Zuckerman, from press clippings that

7 I've seen, was charged and pled guilty to a 20- to

8 $50 million fraud called "Operation Lease Fleece."

9 Therefore, he told me that he had a

10 $10 million restitution and that he had distributed

11 all of his assets into three irrevocable trusts with

12 the trustees being Aaron Thomas, Cameron Verdi, and

13 Ryan Page.

14 Q Do you know how much money was in those

15 trusts?

16 A I don't know the dollar amount.

17 Q Do you know what state those trusts are

18 located in?

19 A I don't know that. He just explained the

20 irrevocable trust; that once he gets out from prison,

21 that they were going to reconstitute all of his

22 holdings for him, and it was a way for him to subvert

23 the system.

24 Q Zuckerman told you that was a way for him to

25 get around restitution?



198

1 A Restitution, any other future actions.

2 I also have a audio recording, which is he

3 and Ryan Page checking extradition laws and where

4 they're going to set up their new company. At the

5 time, they were talking about Cyprus. So he's

6 planning on going outside the country after he gets

7 out of prison.

8 Q So Ryan Page and Aaron Thomas are in charge

9 of the trust. Anyone else?

10 A Cameron Verdi.

11 Q Anyone besides those three people?

12 A Those are the only three people that he told

13 me about.

14 Q Did he tell you who would activate

15 metrxman.com if he was in prison? I'm referring to

16 Adam Zuckerman.

17 A It would be Ryan Page and Lori Wildrick.

18 And then there's a person, supposedly outside the

19 company, under the name of Reese. I've never spoken

20 to Reese. I've only had Adam refer to Reese, who is

21 supposed to have the ascottconnelly.com, the

22 vinceandrich.net, and the anthonyroberts.org.

23 Q But you don't know where Reese is located or

24 have an address?

25 A It's either Panama or Paraguay.



199

1 MR. SYVERSON: Let's mark this MM. I

2 believe that is where we're at.

3 (Exhibit MM marked.)

4 BY MR. SYVERSON:

5 Q This is a July 27th, 2010, e-mail from Adam

6 Zuckerman to Darren Meade. And the subject line is

7 "The Meade Misdeed."

8 So when you've had an opportunity to review

9 this, let me know.

10 A I've reviewed it.


12 A Yes.


14 A This is an e-mail from Adam Zuckerman to

15 myself. Adam had drafted an e-mail to Scott Connelly

16 pretending to be me and was sending it over to me to

17 review.

18 Q Do you know if this e-mail was ever sent to

19 Scott Connelly?

20 A It was never sent. I believed it was

21 inappropriate. Adam wanted me to send it, but I did

22 not.

23 Q Is there anything else significant about

24 this e-mail, in your mind?

25 A Well, it's a precursor to the defamation



200

1 website that came up ascottconnelly.com. Also, I

2 believe the WordPress blog is scottconnellyscam.com.

3 I'm not sure if I have that other domain correct.

4 Q You've mentioned audiotapes both in Volume I

5 and Volume II. Is there a way that we can easily

6 obtain those from you? Can you put those on a CD for

7 us, for instance?

8 A I can invite you into the drop box which has

9 the unedited tapes, and I can also e-mail you the

10 snippets that I've been referring to along with the

11 time markers so then you can verify them on the tapes

12 as well.

13 Q Okay. This is Exhibit NN. It is a

14 August 6, 2010, e-mail from Adam Zuckerman to a

15 number of people, including Ryan Page. A number of

16 people are copied on this, including yourself.

17 Again, same instructions. When you've had

18 time to review it, let me know.

19 (Exhibit NN marked.)

20 THE WITNESS: I have reviewed it.

21 BY MR. SYVERSON:


23 A Yes, I am.


25 A This is a document from August 6 from Adam



201

1 Zuckerman to Ryan Page; Michael Brown, who was an

2 attorney for Progenex; Lori Wildrick; Aaron Thomas;

3 and myself.

4 Q Okay. What is the significance of this

5 e-mail or why is it relevant to -- strike that.

6 What is the significance of this e-mail?

7 A The significance of this e-mail is it shows

8 that Adam was actively lying and misrepresenting that

9 Body Rx was going to compete with Progenex and that

10 that was a secret company or something that Scott was

11 trying to do illegally.

12 The reason why I state that is I was misled

13 as the CEO and told that the only document that was

14 ever signed was an agreement to negotiate in good

15 faith. That wasn't true. The Body Rx brand actually

16 was known that it was going to come up and compete

17 within the marketplace.

18 But this is just an e-mail showing that

19 Adam's untruthful, not only to myself but to, you

20 know, also to the company attorney, Michael Brown.

21 Q Help me understand that. I don't understand

22 that. So how does it show that Zuckerman was being

23 untruthful?

24 A This was Adam writing that -- that Scott's

25 plan was, you know, to compete with Body Rx. What



202

1 happened in the contract that was signed between

2 Scott Connelly and Body Rx, it was always known that

3 Body Rx was going to compete in the same marketplace.

4 Q I'm sorry to interrupt you. Did you mean

5 contract between Scott Connelly and Progenex?

6 A Yes. I apologize.

7 Q And so -- you may have already elaborated on

8 this earlier, but -- well, explain the Scott Connelly

9 contract with Progenex in brief terms.

10 A This is a difficult question only because

11 there's -- I later found out so much more in regards

12 to what Adam Zuckerman does with something called "An

13 agreement to negotiate in good faith."

14 Q And we talked about that earlier, and you

15 don't have to go back into that. I guess what I'm

16 interested in is: As CEO of Progenex, what did you

17 understand this contract between Connelly and

18 Progenex to be?

19 A I understood it -- that there was just an

20 agreement to negotiate in good faith, which meant

21 that Progenex, at the time, actually controlled all

22 the product, the names, patents, and everything else

23 of Scott Connelly.

24 This was an e-mail -- and I'm going to use

25 the word "indoctrinating" -- but it's indoctrinating



203

1 me again that Scott was going to compete with the

2 Body Rx brand against Progenex.

3 Q And Adam led you to believe that was wrong

4 because Scott's agreement with Progenex prevented him

5 from competing with Body Rx?

6 A Correct. And I later found out that wasn't

7 true.

8 Q How did you find out that it wasn't true?

9 A When I resigned from Progenex, I reached out

10 to Scott Connelly and Vince Andrich. I actually

11 reached out to them a week before I resigned. I

12 didn't call them personally. I had somebody reach

13 out to them and say, "Darren Meade's going to be

14 resigning in a week. It's not a stunt, and whatever

15 you do, please don't settle until we had a chance to

16 sit down and talk."

17 The reason why I mention that is I had a

18 $200,000 bonus provision if I made Scott Connelly

19 settle with Progenex. We had a mediation on

20 January 13th and Scott Connelly had actually agreed

21 to settle, and it would have triggered a $200,000

22 bonus to myself.

23 But I found out that Adam Zuckerman was

24 planning to defraud another person named Michael

25 Roberts. And I say, "planning to defraud," because

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204

1 Michael Roberts brought me a contract that he had

2 signed with Adam Zuckerman.

3 And when I saw it, my stomach physically

4 turned because it was essentially the same document

5 in Scott Connelly's pleadings against Progenex. And

6 I realized that it was a cookie-cutter fraud and that

7 I was on the wrong side of all of this.


9 Exhibit NN other than the fact that you believed that

10 this revealed that Adam was not being truthful with

11 you?

12 A No.

13 MR. SYVERSON: This will be Exhibit OO.

14 (Exhibit OO marked.)

15 THE WITNESS: I think this is a duplicate.

16 BY MR. SYVERSON:

17 Q I believe this is a duplicate.

18 Okay. Exhibit OO, this is an e-mail dated

19 August 17, 2010, from Adam Zuckerman to Michael

20 Brown. A number of people are copied on this,

21 including yourself.

22 When you've had a chance to review it, let

23 me know.

24 A I've reviewed it.


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205

1 A Yes, I am.


3 A This was an e-mail from Adam Zuckerman to

4 Michael Brown, myself, Ryan Page, and then Lori

5 Wildrick, Aaron Thomas, Frederick Gaston. It is

6 pertaining to Adam getting ready to draft a series of

7 actions coming from the investors.

8 Q Okay. Why would Adam be drafting actions

9 for the investors?

10 A Adam controlled Ken Barnes. Ken Barnes was

11 the attorney for Venture Pharma. That is one of the

12 groups that invested into Progenex. There was also

13 Shared Success. But I was told all of the investors

14 in Shared Success are in Venture Pharma even if they

15 didn't invest any money.

16 Q So what did you understand it to mean when

17 Adam says in the second sentence, "We've been keeping

18 the traffic down on your side to allow you some

19 (undeserved) rest," smiley face?

20 A That's in regards to Michael Brown, who went

21 to go on vacation. I believe it was to Hawaii.

22 Keeping traffic down was in regards to some negative

23 attacks that were coming out on the Progenex side

24 towards Dr. Connelly.

25 Q So as you understood it, this is Adam



206

1 telling Michael, "Hey, we're, you know, we're taking

2 a break from our normal Internet defamation campaign

3 while you're away"?

4 A Correct. And it was also what I consider

5 another patently false e-mail from Adam talking

6 about, you know, Dr. Connelly trying to bankrupt the

7 company and saying that he was going to try and file

8 it under the investors', you know, competition under

9 the Business and Professions Codes.

10 There's an e-mail that I didn't bring, which

11 is Adam talking about an article he had just read on

12 business torts. And this e-mail here is essentially

13 a manifestation after he read on business torts, a

14 new action that he thought he'd bring against

15 Dr. Connelly.

16 Q And who's Frederick Gaston?

17 A Frederick Gaston is a contingency attorney

18 that was brought in because we were trying to cap the

19 expenditure that we were spending on attorneys' fees.

20 Q Did he represent Progenex?

21 A He did.

22 Q Does he still represent Progenex?

23 A I believe that he's no longer representing

24 Progenex.

25 Q Could I ask you to turn to page 2 of this



207

1 exhibit.

2 A Yes.

3 Q And this is an e-mail from Ryan Page to,

4 among others, Adam Zuckerman and yourself. What is

5 the significance of this e-mail?

6 A There's a few different significances. One,

7 you'll notice that Adam Zuckerman is Adam Stuart. I

8 only point that out because he continually utilized

9 an alias.

10 Secondly, this is Ryan Page announcing that

11 he found an article in regards to Dr. Connelly's

12 education background, and he was asking me to do some

13 research in regards to a Dr. Demling.

14 And the reason I am just pointing this

15 out -- eventually, I resigned from Progenex.

16 Unfortunately, I resigned twice because I was talked

17 into coming back into the company. But Adam

18 eventually posted some information on

19 ascottconnelly that I was opposed to and I thought

20 was over the line, and that was one of the main

21 reasons I resigned initially in December.

22 Q Okay. So this August 6 e-mail from Ryan

23 Page to yourself and Adam Zuckerman is essentially

24 more of the same coordinating, talking about how to

25 post more defamatory content?



208

1 A More defamatory content.

2 And I'd like to just point out, you'll

3 continually see, when we're talking about defamatory

4 content, the name Lori Wildrick. Because she was one

5 of the main content writers. And as I mentioned

6 earlier, I read some of her articles for

7 metrxman.com.

8 Q Do you know, was she an employee of Progenex

9 or an independent contractor? Do you know?

10 A Progenex is interesting because they -- they

11 claim to never have any employees and that

12 everybody's under an independent contractor. She was

13 the director of marketing paid $9,000 a month.

14 When I became CEO of the company, I felt

15 that she didn't really have any skill set except

16 writing defamatory articles, and we moved her down to

17 an independent contractor on per-piece work.

18 Q So before that, she was an employee?

19 A She had an executive title as "Director of

20 marketing." So you're going to have to -- it's going

21 to depend on what your definition of an employee is.

22 Q Okay. Well, let me ask you this as CEO.

23 You may or may not know. Without regard to titles,

24 do you know if she was paid as an employee, had taxes

25 withheld, etc.; or was she paid as an independent



209

1 contractor, "Here's a check, you take care of your

2 taxes and deductions"?

3 A It was a 1099 and they went out of their way

4 to make sure you had to bring your own laptops into

5 the office. So they were setting up so everybody was

6 an independent contractor, not an employee.

7 MR. SYVERSON: Thank you.

8 This will be PP.

9 (Exhibit PP marked.)

10 BY MR. SYVERSON:

11 Q This is a September 16th, 2010, e-mail.

12 This is from Adam Zuckerman to yourself and Ryan

13 Page, Aaron Thomas copied.


15 A Yes, I am.


17 A This was Adam letting us know that he had

18 been on Fiverr, which is a place where you can find

19 people for a very low amount of money to do

20 projects. He wanted to come up with some derogatory

21 drawings to be able to put on websites.

22 And in this regard, he found someone that

23 would draw whatever you want for $5.

24 Q And I believe we discussed some of those

25 drawings that eventually were made in Volume I; is



210

1 that correct?

2 A Yes.

3 And could I mention one thing about that?

4 Q Sure.

5 A This is in September. This is showing

6 Adam's planning on coming up with the defamatory

7 websites. The drawings that were made that we

8 discussed previously were from a gentleman named

9 Matthew. And he did some drawings of -- forgive

10 me -- masturbation and penises and so forth. And

11 that was published on two websites.

12 MR. SYVERSON: And I believe those are

13 already in the record.

14 Let's mark this QQ.

15 (Exhibit QQ marked.)

16 BY MR. SYVERSON:

17 Q QQ is an e-mail from Ryan Page to yourself,

18 among many other recipients, on September 24th,

19 2010.


21 A Yes. I'm familiar with it. And to be

22 honest, it's a somewhat insignificant document. It

23 was someone that had made a transcription -- and

24 again, I'm actually trying to think who I provided

25 this to. There's not a huge relevance to it, so I



211

1 apologize.

2 Q Okay, we'll move on. If you think of

3 anything that is relevant, please let me know.

4 MR. SYVERSON: This will be RR.

5 (Exhibit RR marked.)

6 BY MR. SYVERSON:

7 Q This is an October 3rd, 2010, e-mail from

8 Adam Zuckerman to yourself and others.


10 A Yes, I am.


12 A This is a document from Adam Zuckerman, and

13 he is updating us that a lady named Marni who works

14 for a website called "GenXXL," that he had a

15 conversation with her. He identified her as a cool

16 person. The only reason why that's significant is

17 Adam wound up working with GenXXL.

18 A person named Sean and whoever the owner of

19 GenXXL is, from my understanding, was a -- another

20 convicted felon, but he was based out of Israel; and

21 they agreed to post a series of defamatory articles

22 on Dr. Scott Connelly.


24 this e-mail?

25 A What will happen later on is you'll see some



212

1 other documents that the relationship has -- had

2 progressed and that Adam was drafting articles along

3 with Ryan Page, Aaron Thomas, and Lori Wildrick,

4 which were posted on the Internet.

5 MR. SYVERSON: This will be SS.

6 (Exhibit SS marked.)

7 BY MR. SYVERSON:

8 Q This is an October 5th, 2010, e-mail.

9 "Subject: Con-Air," from Adam Zuckerman to yourself

10 and Ryan Page. Michael Brown is copied.


12 A Yes, I am.


14 A This is a document from Adam Zuckerman, as

15 you mentioned, to myself, Ryan Page, and Michael

16 Brown. It was a draft of a story that Adam

17 essentially wrote. Marni did provide some ghost

18 writing and Adam is asking if I will build in a

19 conspiracy angle to it.

20 Q And what would be the conspiracy angle?

21 A He was trying to get me to write about some

22 issues that Scott Connelly and I had litigated about

23 in the past. I didn't do that, nor did -- nor did

24 Shannon. It was just another request of Adam that,

25 you know, I personally ignored.



213

1 And he eventually went ahead -- and I

2 believe it's a total of four articles that he posted

3 up on GenXXL.

4 Q Okay. This e-mail has an attachment to it,

5 but we don't have the attachment; is that correct?

6 At least we don't have it printed out with us.

7 A Yeah, I don't have it printed out, but I'll

8 make a note, and if there's an attachment, I'll send

9 it to you.

10 Q Okay, thank you.

11 What is Shannon's last name?

12 A Shannon Juarez.

13 Q Do you know if this article that was

14 attached to this was ever posted on this GenXXL.com?

15 A Yes, it was posted.

16 MR. SYVERSON: This will be TT.

17 (Exhibit TT marked.)

18 BY MR. SYVERSON:

19 Q This is an e-mail string dated December 7th,

20 2010, from [email protected] to yourself.

21 A Correct.


23 A Yes, I am.


25 A This document is an e-mail to myself from



214

1 pr@progenexusa and also to Ryan Page. Now, it's

2 supposed to be from a Bella Fitzgerald. Bella

3 Fitzgerald is actually Christine Ireland, who worked

4 for a company called "X-Banker," also Progenex USA.

5 And I'm not sure if we covered it in

6 Volume I or if we're going to cover it today, but

7 this was the person who set up numerous e-mail

8 accounts to be able to post defamatory information on

9 Dr. Connelly.

10 Q We did discuss that previously.

11 So [email protected], that is from

12 Christine Ireland, this e-mail?

13 A Correct.

14 Q And the link, socialtimes.com, is there any

15 significance with regard to that link?

16 A I apologize. I'm not sure. Because it says

17 "video," I don't think that there is any significance

18 to it.

19 What I wanted to point out was just the use

20 of an alias by Christine Ireland; that she was

21 posting information.

22 And then you have a handwritten list and

23 some different communications of her to me that she

24 had set up all of these accounts to be able to post

25 the derogatory information.



215

1 MR. SYVERSON: This will be UU.

2 (Exhibit UU marked.)

3 BY MR. SYVERSON:

4 Q This is a December 11th, 2010, e-mail from

5 Ryan Page to yourself. The subject is: "I heard

6 through the grapevine."


8 A Yes, I am.


10 A This document is an e-mail from Ryan Page to

11 myself. As I had mentioned, I had resigned from the

12 company. Part of that decision was based on some

13 derogatory material that went up on Scott Connelly

14 and also my becoming alarmed with Adam Zuckerman.

15 And Ryan was just stating that he was disappointed

16 that he had to learn about my decision from the

17 attorney, which was Michael Brown.

18 Q Michael Brown was Ryan Page's attorney?

19 A He was Progenex' attorney.

20 Q So when he says, "from" -- when Ryan Page

21 says, "from my attorney," did you understand that to

22 mean that Michael Brown represented Ryan Page as an

23 individual or Michael Brown simply represented

24 Progenex?

25 A I believe Michael Brown represented



216

1 Progenex.

2 Q And the statement, "and a cc'd e-mail to a

3 contractor," who is this contractor that Mr. Page is

4 referring to?

5 A I contacted a few contractors. I would have

6 to go back and look at my initial e-mail to see who I

7 cc'd.


9 this e-mail?

10 A This e-mail's more of a placeholder. We'll

11 look at some documents, or they were introduced

12 earlier, where Adam was apologizing for information

13 he had posted on ascottconnelly.com and

14 anthonyroberts.org. And part of his apology is that

15 he immediately removed the material that I found

16 offensive.

17 Q And in fact, you did not quit Progenex at

18 this time; is that correct?

19 A I did resign. Unfortunately, I came back

20 until February. I was essentially lied to. The

21 tapes that I mentioned that I have that I'll send to

22 you, you'll listen to Adam gloat about how he lied

23 and manipulated me to come back.

24 MR. SYVERSON: Let's take a break here.

25 (Recess.)



217

1 MR. SYVERSON: Here is VV.

2 (Exhibit VV marked.)

3 BY MR. SYVERSON:

4 Q VV is an e-mail on January 7, 2011, from

5 Adam Zuckerman to yourself.

6 A Yes.


8 A Yes, I am.


10 A This is a document from Adam Zuckerman.

11 There's two points of significance with

12 this. One probably just pertains to myself. But I

13 had resigned, was talked into coming back, and Adam

14 is promising to get stock to me, essentially saying

15 that, you know, sales have been exploding. The

16 company, as I mentioned, was about to go insolvent

17 when I came in as CEO.

18 But you have the "friends of Aaron." Aaron

19 Thomas had filed a bankruptcy, and what happened with

20 this is Adam essentially wanted me to take some of

21 Aaron's stock and hold it for him and then transfer

22 it back to him after the bankruptcy was over.

23 Q So that would be -- he was asking to you

24 circumvent the bankruptcy court?

25 A Correct.



218

1 Q Did you do that?

2 A No.

3 And then the second part of this is going

4 into the Ripoff Reports. This has some significance

5 only because there's a gentleman named Michael

6 Roberts. There's a company called "Rexxfield." This

7 was the gentleman who, when I saw the contract that

8 he signed, I realized that Scott Connelly was a

9 victim. I say that because the agreements to

10 negotiate in good faith were almost identical.

11 Part of what he had was a source code that

12 would allow Ripoff Reports to no longer be seen on

13 the Internet. The only reason why that's important

14 is because Ripoff Reports never deletes anything

15 written about somebody. So it's the perfect place to

16 defame somebody because it will always stay up, and

17 for some reason it winds up ranking on the first page

18 of Google. So if you want to destroy somebody's

19 reputation, that's a great place to do it.

20 Adam is referencing Sam Krane. Sam Krane is

21 an attorney of Dr. Connelly. And he's saying that

22 Sam Krane demanded that these derogatory reports be

23 removed and Adam essentially is writing rhetorically,

24 "Do you know who posted these and do you know anyone

25 who Connelly can hire to remove?"

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219

1 That's because the new business entity with

2 Michael Roberts would have the ability to remove

3 those reports.

4 Q So you understood these comments by

5 Zuckerman to be facetious?

6 A Correct. He thought it was going to be with

7 great irony that the only way Scott Connelly could

8 have these defamatory reports removed would be to pay

9 Adam's new company.

10 Q Do you know if Ripoff Reports knew what you

11 guys were up to?

12 A According to Michael Roberts, he notified

13 them of what the technique was. So I'm not sure.

14 The only reason I say "I'm not sure" is my

15 understanding is that if they reversed the source

16 code, then you'd be able to see these reports again.

17 And some people that I know that paid for the

18 services, the negative reports didn't come back up.

19 MR. SYVERSON: So we're on W -- WW.

20 (Exhibit WW marked.)

21 BY MR. SYVERSON:

22 Q This is a January 19th, 2011, e-mail titled

23 "Take a look," from Adam Zuckerman to yourself. And

24 it looks like it has an attachment which is not

25 attached to this document.

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220


2 A Yes, I am.

3 Q And what is it?

4 A I had just mentioned a company called

5 "Rexxfield," and previously I have mentioned a

6 contract to negotiate in good faith. This is a copy

7 of that document that was provided to me, and this is

8 when I began to realize that Scott Connelly was

9 actually a victim of Adam Zuckerman.

10 Q That is because why?

11 A There's actually a host of victims of Adam

12 Zuckerman that I didn't know at this time. The --

13 this contract is almost identical to the one that

14 Dr. Connelly signed. Adam was searching out for

15 victims that had some type of original IP or work

16 product that was tied very strongly into their

17 personality. This contract to negotiate in good

18 faith he would utilize as a leverage point where now

19 that image was locked up.

20 So the reason why I say that I started to

21 realize that Dr. Connelly was a victim is I was

22 interacting with Michael Roberts -- and actually the

23 one that sourced him initially as a potentially deal

24 structure because I was told that Adam Zuckerman and

25 Ryan Page controlled a $5 million fund to be able to

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221

1 incubate new projects.

2 And this contract locked up Michael Roberts

3 in the same way that Dr. Connelly alleged in some of

4 his pleadings.

5 Q And is Adam Zuckerman asking you in this

6 e-mail to provide edits or simply review it so you'd

7 have knowledge of it?

8 A So I'd have knowledge of it.

9 MR. SYVERSON: This will be XX.

10 (Exhibit XX marked.)

11 BY MR. SYVERSON:

12 Q This is a June 20th, 2011, e-mail from

13 yourself to yourself. It looks like it was

14 forwarded.

15 A Correct.

16 Q And is this an e-mail string that you simply

17 forwarded to yourself?

18 A Yes.

19 Q And you did that in preparing your response

20 to our deposition subpoena and request for documents?

21 A Correct.

22 Q When you've had a chance to look at it, why

23 don't you let me know if you're familiar with this

24 document.

25 A Yes, I'm familiar with it.

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222


2 A Well, this is a string. The initial one is

3 from Lori Wildrick to myself and Adam Zuckerman. And

4 she was providing information that could be utilized

5 in a defamatory way against Vince Andrich and Scott

6 Connelly.

7 Lori's job essentially was to dig up dirt,

8 if you will, and then to draft it into a written

9 form.

10 The next part in this chain is actually

11 where Adam was impressed with some of the things that

12 Lori was digging up and going to give her a $500

13 bonus.

14 Q Is that what is referenced in the August 6,

15 2010, 9:26 p.m. e-mail from Adam to Lori Wildrick?

16 A Correct.

17 And then on August 7, 2010, you'll see that

18 Lori wrote to Adam; Michael Brown, who is her

19 attorney; Ryan Page; and Aaron Thomas. And she's

20 referencing here a person -- that's David Meltzer, it

21 just has his last name -- and the Leigh Steinberg

22 Sports & Entertainment Group.

23 Q So what is that relevant to? Help me

24 understand that.

25 A You have to remember that Lori's job was to



223

1 dig up defamatory information that could be published

2 at a later date. So when you read it, you'll see

3 that -- she's referring to Meltzer. "Here's the guy

4 who basically said, 'We need your cash or we won't be

5 able to shop the deal.' That didn't come from" --

6 Q Can I stop you there?

7 A Sure.

8 Q I'm lost. I don't know what that means.

9 Who is Meltzer?

10 A It's Dave Meltzer who was going to become

11 the CEO of Progenex.

12 Q When was he going to become the CEO of

13 Progenex?

14 A Prior to myself and during the time that

15 Scott Connelly was still there.

16 Q Okay. And it didn't work out for some

17 reason?

18 A It didn't work out. And this was going to

19 be something derogatory that they could publish about

20 David Meltzer.

21 Q Okay. So Lori -- what would be the purpose

22 of publishing defamatory content about David Meltzer?

23 A At the time, it was trying to get David

24 Meltzer to go ahead and do a declaration that would

25 be more favorable to Progenex.



224

1 Q More favorable in what sense? In

2 litigation?

3 A Yes, in the litigation. So it would be

4 something that would put Progenex into a positive

5 light and Scott Connelly into a negative one. They

6 were very worried that David Meltzer could provide a

7 declaration that would be damaging to them.

8 Q I see. So it's basically a shakedown,

9 "Either give us a declaration or we'll trash you on

10 the Internet"; is that the idea?

11 A Yeah. The idea is to destroy your business

12 reputation and make it to you're unable to have

13 gainful employment.

14 Q Do you know if they ever posted defamatory

15 content about Meltzer?

16 A No. I was told that Meltzer wound up doing

17 a declaration with Michael Brown. I never saw it, so

18 I'm not sure if that's true. I was just told by Adam

19 that he capitulated.


21 this e-mail?

22 Let me ask you this: On page 2 there's an

23 August 6th e-mail from Lori Wildrick at 6:59 p.m. It

24 states, "Have we unearthed any evidence that

25 disproves Scott's medical degrees?"



225

1 Do you see that?

2 A Yes.

3 Q What is that in reference to?

4 A That's in reference to a defamatory piece

5 that will come out in the future talking about

6 Scott's medical degrees.

7 Q The idea was to disparage or defame

8 Mr. Connelly's educational degrees?

9 A Correct. This is the early planning of, you

10 know, what came out later in the year.

11 Q And did that content eventually come out?

12 A Yes.

13 Q The August 6, 2010, e-mail at 7:06 p.m.

14 states, "Xvulture wrote: Darren is the snake on this

15 path."

16 What does that refer to?

17 A That was -- as in the previous e-mail where

18 Adam had drafted an e-mail that he wanted me to send

19 to Scott on himself. He felt that I would be able to

20 provide some information from my previous litigation

21 with Scott.

22 MR. SYVERSON: We are up to YY.

23 (Exhibit YY marked.)

24 BY MR. SYVERSON:

25 Q YY is an e-mail string. It looks like it



226

1 was forwarded to yourself on June 20th, as you have

2 with other exhibits.

3 Did you do this in gathering information

4 responsive to our subpoena?

5 A Yes, I did.

6 Q Take a minute to review this document. When

7 you've had a chance, please let me know if you're

8 familiar with this document.

9 A Yes, I've reviewed it.

10 Q Okay. So let's start with the

11 September 5th, 2010, e-mail at the top of page 1 from

12 Adam Zuckerman to yourself.

13 Can you tell me what this e-mail is?

14 A This is an e-mail, as you mentioned, from

15 Adam to myself, Ryan Page, and Aaron Thomas. It's

16 from Marni McNiff, the editor in chief of GenXXL.

17 And as I had mentioned previously, Adam wound up

18 enlisting the owner of GenXXL that published a series

19 of defamatory articles on Scott Connelly, and this is

20 just Marni saying that she'll get a story as soon as

21 she receives it.

22 Q Is this an e-mail that was

23 forwarded? because the e-mail looks like it was from

24 Adam Zuckerman to you. Is it a cut-and-paste of a

25 Marni McNiff e-mail to Adam Zuckerman?



227

1 A Adam's sending it to me, so yeah, it's a

2 cut-and-paste from Marni just updating us that he's

3 been able to get the defamatory information up.

4 Q What about the e-mail below it?

5 [email protected] to [email protected].

6 A The [email protected] is an alias

7 that Adam Zuckerman was utilizing. So this is a

8 continuation just of him providing his information

9 that he was having with Marni McNiff, who was the

10 editor in chief of GenXXL.

11 Q And the subject of this e-mail is:

12 "National story about Scott Connelly, founder of

13 Met-Rx."

14 Is this in reference to a planned story to

15 appear on GenXXL?

16 A Yes, it is.

17 Q At the bottom of page 1 it's an e-mail from

18 Adam Zuckerman to Ryan Page. You were copied on it.

19 The subject is: "New team member."

20 Can you tell me what this e-mail refers to?

21 A This is an e-mail from Adam Zuckerman

22 stating that Marni McNiff was now a team member. And

23 so it would be a team member of Progenex to be able

24 to run defamatory information.

25 Q So now she's on board and a member of the



228

1 team that's mission is to defame Scott Connelly

2 online; correct?

3 A Correct.

4 MR. SYVERSON: Can we take a break?

5 (Recess.)

6 MR. SYVERSON: This will be ZZ.

7 (Exhibit ZZ marked.)

8 BY MR. SYVERSON:

9 Q This is a June 20th e-mail from yourself to

10 yourself.

11 Again, is this in gathering documents

12 responsive to the subpoena?

13 A Correct.

14 Q And what you have forwarded to yourself is a

15 January 18th, 2011, e-mail from Adam Zuckerman to

16 Aaron Thomas and you are copied on it.


18 A Yes, I am.


20 A It's a document from Adam Zuckerman to Aaron

21 Thomas. I'm cc'd on it.

22 As I had mentioned previously, Aaron Thomas

23 and Lori Wildrick were the primary editors for any

24 defamatory information coming out. And this is Adam

25 saying not to post yet, that he wanted to review a



229

1 letter that had been drafted.

2 Q And is the draft of the letter attached to

3 this e-mail?

4 A Yes, it is.

5 Q Those are the following pages?

6 A Correct.

7 Q And was the idea to post this letter

8 somewhere?

9 A It was to have this go online, but one of

10 the edits that Aaron Thomas made was to switch it

11 from fictional Leonard Katzman to Dr. Scott Connelly.

12 Q I see. So the letter would be about Scott

13 Connelly and defame Scott Connelly?

14 A It was going to be a letter claiming to be

15 from Scott Connelly.

16 Q So impersonating Scott Connelly?

17 A Correct.

18 Q Do you know if this was ever posted on the

19 Internet?

20 A I believe it was.

21 Q Do you know where it was posted on the

22 Internet?

23 A I'd have to check my notes to get the -- I

24 believe it was just posted within some forms and

25 online. I don't believe that this was ever posted on



230

1 the ascottconnelly.com site.

2 Q And if you know, what would be defamatory

3 about this letter? What was the goal?

4 Let me ask you this: Why produce this

5 content as a letter and falsely ascribe Scott

6 Connelly as the author?

7 A This was going to be a defamatory piece that

8 was to be a spoof on the WGFE, which was an

9 ingredient that Dr. Connelly has a patent on; to also

10 defame Vince Andrich; and to essentially take any

11 type of story or any type of copy that would come out

12 and make fun of it in advance, thereby affecting the

13 marketplace for WGFE.

14 Q I see. So the idea was to take a hit at

15 this WGFE product; correct?

16 A Correct.

17 Q And as you understood it, they took an

18 article or an open letter that had already been

19 published?

20 A Correct.

21 Q And simply changed out Mr. Katzman's name

22 for Dr. Connelly's name?

23 A Well, they also -- there's content tying in

24 Met-Rx in a derogatory way, so there's other changes

25 within the article. It was just taking the format.



231

1 Q So one of the goals was to make it look as

2 though Dr. Connelly was disparaging Met-Rx products?

3 A Disparaging himself.

4 Q I thought you said Met-Rx products?

5 A Met-Rx is defamed in here as well, as is

6 Vince Andrich.


8 this draft that's attached to this e-mail?

9 A As I mentioned, just a continuation showing

10 that Aaron Thomas would edit the material.

11 MR. SYVERSON: Now might be a good time to

12 take that break.

13 * * *

14 (LUNCHEON RECESS)

15 * * *

16 MR. SYVERSON: Okay. AAA.

17 (Exhibit AAA marked.)

18 BY MR. SYVERSON:

19 Q So AAA is an e-mail from Adam Zuckerman to

20 Ryan Page. You, Mr. Meade, are copied on it. It

21 was -- the date of the e-mail September 26, 2010.


23 A Yes, I am.


25 A This document's in regards to something



232

1 called "Con-Air." And on the October 5th, 2010,

2 document that we already entered, this is talking

3 partially about the attachment. This was on

4 derogatory articles that would come up on

5 ascottconnelly.com.

6 In this one, Ryan Page is mentioning that he

7 wanted to have the injection and prostitution letters

8 to go out before we would settle, because he wanted

9 to make sure that those would be out in public.

10 Those are currently up on ascottconnelly.com.

11 Q Okay. Let's take a couple pieces of this.

12 What is the Con-Air clan? What does that

13 mean?

14 A Con-Air clan was going into a radio program

15 that was done on Super Human Radio, I believe. The

16 purpose was to link Scott Connelly with convicted

17 felons.

18 Q So what does -- I guess I'm just asking, who

19 is the Con-Air clan?

20 A Would be Scott Connelly, Dave Palumbo, John

21 Romano, Vince Andrich.

22 Q And so "Con-Air" refers to that group?

23 A Correct.

24 Q Is Con-Air a reference to Scott Connelly?

25 Is that a shortening of his last name?



233

1 A That was a -- yes. Adam liked to break up

2 Scott's name so that it was C-o-n, hyphen, and then

3 the remainder of his last name.

4 Q Let's go with the injection letters. What

5 are the injection letters referring to?

6 A There was a gentleman named Mike Hayes that

7 was convicted of extortion of Scott Connelly. He had

8 some letters that were alleging that Scott Connelly

9 had hired hookers and also was taking injections of

10 something called "prostaglandin." I'm not sure if I

11 pronounced that correctly.

12 Q And so Ryan Page is discussing releasing

13 those copies of those letters to the public or

14 referring to them in public?

15 A Yes.

16 And the other part of this letter is one

17 line up above it, "...so it doesn't look like GenXXL

18 is the only party interested in our story." So it

19 was talking about finding some other outlets for the

20 defamatory information.

21 Q And was that to provide further -- or the

22 veneer of legitimization of the defamatory content?

23 A Correct.

24 MR. SYVERSON: This is BBB.

25 (Exhibit BBB marked.)



234

1 BY MR. SYVERSON:

2 Q BBB is a September 26, 2010, e-mail from

3 Adam Zuckerman to yourself, Ryan Page, and Aaron

4 Thomas.


6 A Yes, I am.


8 A It's an e-mail from Adam Zuckerman letting

9 us know that he was now working with a gentleman

10 named Sean over at GenXXL. GenXXL was where the

11 initial defamatory articles on Scott Connelly were

12 posted, and this is just a confirmation e-mail that

13 he would be working with us.

14 Q So GenXXL was sort of the opening shot in

15 the defamation campaign?

16 A Correct.

17 MR. SYVERSON: This will be CCC.

18 (Exhibit CCC marked.)

19 BY MR. SYVERSON:

20 Q CCC is a September 24th, 2010, e-mail from

21 Adam Zuckerman to yourself, Mr. Meade. Others are

22 copied on it.


24 A Yes, I am.




235

1 A It's an e-mail from Adam Zuckerman to me.

2 The purpose of it is that an editor and

3 proofreader would be assigned to anything that I put

4 together. And then it particularly references Aaron

5 Thomas, that he's great with that specific skill

6 set.

7 And as I had mentioned earlier, Aaron Thomas

8 wound up editing all the defamatory information that

9 went up.

10 Q This is in reference to the creation of

11 defamatory content about Dr. Connelly?

12 A Correct.

13 Q And did you understand this to mean that

14 Lori Wildrick would not be doing much from that point

15 forward?

16 A It was more -- there's two parts to this

17 e-mail. I was also creating positive PR for

18 Progenex. So she wouldn't be working with me on the

19 positive information.

20 Q But she would still be -- you understood

21 this to mean that Lori Wildrick would still be

22 creating defamatory content?

23 A Yes. She was the primary copywriter for the

24 metrxman.com website.

25 Q I think I neglected to provide the court



236

1 reporter and yourself with page 2 of this CCC

2 exhibit. Is that, in fact, page 2 of this document,

3 CCC?

4 A Yes.

5 And in that -- just as a point of reference,

6 there's a "Mark and Kirk are talking to all their

7 peeps."

8 Kirk McMahon is another convicted felon

9 co-conspirator with Adam Zuckerman on something

10 called "Operation Lease Fleece. I'm just pointing

11 that out because we had multiple convicted felons

12 working together daily at the Progenex office in

13 Costa Mesa.

14 Q With regard to Mark and Kirk, what were

15 their duties, these two convicted felons?

16 A Well, I'm not sure if Mark was a convicted

17 felon. Kirk McMahon was, Paul Arnold, Andrew Medal,

18 and Adam Zuckerman. Kirk --

19 Q Let's stick with Kirk McMahon for now.

20 A Kirk McMahon had two jobs. One was sales

21 with Progenex, and the second one was managing

22 another entity called "The X-Banker."

23 Q What about Andrew Medal's duties?

24 A Andrew Medal was also in sales for Progenex

25 and would also go out to the events, as would Kirk



237

1 McMahon.

2 MR. SYVERSON: Okay. Let's mark this DDD.

3 (Exhibit DDD marked.)

4 BY MR. SYVERSON:

5 Q DDD is a September 10, 2010, e-mail from

6 [email protected], who you have identified

7 here today as being Adam Zuckerman, to yourself.


9 A Yes.


11 A This was Adam Zuckerman writing to me

12 underneath his alias. He had put an ad out on

13 Craigslist trying to get copywriters. This was his

14 request asking me to stay blocked, which would be to

15 block my IP, and to speak with Shannon Juarez, and

16 the other person is a Rebecca. In one of the

17 documents it will have her last name. I never spoke

18 with her. I did speak with Shannon Juarez.

19 Q So was the purpose of blocking and

20 anonymizing your Internet activity so you wouldn't be

21 discovered or traced?

22 A Correct.

23 Q And this is with -- and Shannon Juarez and

24 Rebecca were copywriters that responded to a

25 Criagslist ad?



238

1 A Yes.

2 MR. SYVERSON: This is EEE.

3 (Exhibit EEE marked.)

4 BY MR. SYVERSON:

5 Q EEE is a September 10th, 2010, e-mail from

6 the simmonsmark e-mail address you've identified as

7 Adam Zuckerman, to Rebecca MacLary.


9 A Yes.


11 A This is another e-mail from Adam Zuckerman

12 operating under his alias in regards to putting

13 together information, and some of it could be

14 defamatory, going towards Scott Connelly.

15 Q And is Rebecca MacLary -- is that the woman

16 you were referring to in Exhibit DDD that was

17 referenced in that e-mail without a last name?

18 A Yes.

19 I never met Rebecca. I did meet in person

20 and have meetings and interaction with Shannon

21 Juarez.

22 Q Was there a specific reason why you were

23 hiring outside people to create this content? You

24 devoted -- a lot of time was devoted inside of the

25 organization to producing defamatory content.



239

1 A Yeah. It was Adam's primary job, to do the

2 defamatory content. So he asked me to meet with

3 Shannon in particular. Shannon was a retired police

4 officer. And actually, when she met Adam, who was

5 pretending to be Mark, she told me honestly that she

6 thought he was some type of meth addict or speed

7 freak, wasn't going to do what he requested.

8 And she wrote on the positive PR that I was

9 doing, one piece for sure -- there might have been

10 two positive pieces. So she never wrote anything

11 defamatory, although that's what Adam wanted her to

12 do initially.

13 Q So what was the reason for hiring these

14 outside people? Was there a reason?

15 A Adam's goal was to come up with more

16 defamatory information to be able to post online. As

17 the previous documents explained, he wanted to be

18 able to branch out from GenXXL.

19 Q So it was an issue of volume? He just

20 needed more people hours to produce more defamatory

21 content?

22 A And you need content so it would climb up

23 higher in the search engine rankings.

24 Q Do you have any contact information for

25 Shannon Juarez?



240

1 MR. CONNELLY: Yeah, we've met with her.

2 She's willing to give --

3 MR. SYVERSON: Scott.

4 MR. CONNELLY: Oh, sorry.

5 MR. SYVERSON: We're on the record.

6 MR. CONNELLY: Excuse me.

7 MR. SYVERSON: This is Exhibit FFF.

8 (Exhibit FFF marked.)

9 BY MR. SYVERSON:

10 Q This is a September 10th, 2010, e-mail from

11 Adam Zuckerman, using the simmonsmark e-mail,

12 addressed to yourself.

13 A Yes, I'm familiar with this document.


15 A It is a string of communications between

16 Mark Simmons, aka Adam Zuckerman, with Shannon

17 Juarez.

18 Initially, she was interested in writing

19 about this whole issue. And Adam had put together

20 that there were two options that he was looking for:

21 One was to write about the product; but the other one

22 was, you know, as he had put it, "expose the truth

23 and cover-up," which essentially would be defamatory

24 information.

25 Q On some of these exhibits we're looking at



241

1 today there's some yellow highlighting going on. Are

2 those your -- did you highlight certain aspects of

3 some of these exhibits?

4 A Yeah, I highlighted them on the original

5 copies that I provided you. Just more for me to be

6 able to look and note what I found of interest in the

7 document.

8 Q So those are your notes?

9 A Correct.

10 Q And on some of these that show up on the

11 exhibits, I will note that our copies, the copies

12 that we've made at our office, were full-color

13 copies, and so that highlighting has shown up on some

14 of these exhibits.

15 This will be Exhibit GGG.

16 (Exhibit GGG marked.)

17 BY MR. SYVERSON:

18 Q GGG is a February 22nd, 2011, e-mail from

19 yourself to Adam Zuckerman, and Michael Brown is

20 copied on it.


22 A Yes, I am.

23 Q Okay. What is this document?

24 A This is a document -- there had been a Fox

25 News piece that aired with a gentleman named Michael

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242

1 Roberts and myself. And because the piece aired and

2 I identified myself as the CEO of Progenex, and also

3 Michael Roberts, I wrote to Adam Zuckerman saying

4 that I was worried that Sam Krane would depose

5 Michael Roberts and it could be problematic.

6 So I asked a question of if Michael Brown

7 hired Michael Roberts and was the go-between of all

8 communications, if that might help insulate Michael

9 Roberts.

10 I don't have the e-mail from Michael Brown

11 to Michael Roberts following this. I have seen it

12 and I've asked Michael Roberts for a copy of it, but

13 it's Michael Brown then sending to Michael Roberts a

14 backdated retainer agreement and saying he lost the

15 original, he'd like him to sign it.

16 Q Okay. So that brings up a couple of

17 questions. So as of this e-mail February 22nd, 2011,

18 your testimony is that Michael Brown had not hired

19 Michael Roberts?

20 A Correct.

21 Q Okay. And if you know, what was Michael

22 Brown to hire Michael Roberts for? What services?

23 A He was going to hire him as a consultant and

24 for doing forensics.

25 The other issue of why I pulled this

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243

1 document out is you'll see on page 3, it will say,

2 "You're it, Rexx. Anonymous. Because none of us are

3 as cruel as all of us."

4 What Adam had done is he had gone through a

5 website called "Anonymous Speech" and sent an e-mail

6 to Michael Roberts to make Michael Roberts fearful

7 that one of his business partners was upset with him

8 about the new deal he'd signed.

9 The only reason why this is important is I

10 have another document that will show Adam Zuckerman

11 admitting that he sent the e-mail.

12 Then initially, the Anonymous Speech is tied

13 into the A. Scott Connelly website, the Vince Andrich

14 website, and the anthonyroberts.org. So they're also

15 all based on Anonymous Speech. I have a schematic

16 that ties in IP addresses and everything onto this.

17 I didn't make a copy of it, but I can send it to you

18 as soon as I get back to my home.

19 Q I'm looking at page 2.

20 A So that's the alias that Adam used, "mrr" --

21 with an extra "r" -- "[email protected]."

22 Q So above it we have the subject line:

23 "Congratulations...you made it." And it's from Adam

24 Zuckerman, using the [email protected] e-mail address

25 that we've seen before, to yourself.

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244

1 It says here -- this is Adam Zuckerman

2 saying to you -- "Here is what I sent to Michael

3 because he was freaked about ANON. Should I tell him

4 it's me, LOL."

5 So you understood this to mean that the

6 message below it in the [email protected]

7 e-mail address, in fact, is Adam Zuckerman?

8 A Correct.

9 And just for an irony, I'd like to point out

10 that it's from Adam Stuart, which is another alias of

11 Adam Zuckerman, utilizing another alias to terrorize

12 Michael Roberts.

13 Q And so I don't understand how this would

14 terrorize Michael Roberts. Can you explain that to

15 me?

16 Is page 3 the attachment to the

17 anonymousspeech.com e-mail?

18 A Yes.

19 Q So how would -- as you understand it, how

20 would that terrorize Michael Roberts?

21 A The -- Adam was pretending to be -- he was

22 sending a communication to make Michael think it was

23 Aman, who was another business partner of Michael

24 Roberts. Michael Roberts had just entered into a

25 deal with Adam Zuckerman on a representation

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245

1 management company.

2 However, Aman wasn't a part of that deal, so

3 this was Adam's attempt to make it look as if his

4 business partner was upset with him and was going to

5 wind up defaming him on the Internet.

6 Q I understand.

7 How as you understood it, would that benefit

8 Zuckerman? How would that be to his advantage?

9 A In my opinion, what Adam does is he likes to

10 make it look like other people are attacking you to

11 get you to then believe that he's on your side. I

12 had it happen to me with this Julie Drossman pieces

13 and everything, and I believed that they were coming

14 from Scott Connelly.

15 Scott and I had been business partners

16 roughly 15 years ago, but we hadn't spoken in a long

17 time. And it wasn't until I spoke with him that I

18 could start to put together Adam's tactics, if you

19 will.

20 Q So would this e-mail to Michael Roberts from

21 the anonymousspeech.com e-mail address, would that

22 sort of be planting the first seed in case Zuckerman

23 wanted to mount a defamation campaign down the road

24 against Roberts?

25 A Yeah. It's to try and isolate you from any

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246

1 type of business advisor or anyone that could be a

2 different voice than Adam. To me, it's almost like a

3 husband that abuses a wife or something like that,

4 trying to isolate them out.

5 Q Now, do you have knowledge of Zuckerman

6 using this anonymousspeech.com e-mail address for

7 other activity?

8 A Yes. And I can send you -- it's a schematic

9 that was actually put together by Michael Roberts.

10 It will tie a common IP address into the Anonymous

11 Speech and into the three websites

12 ascottconnelly.com, vinceandrich.net, and

13 anthonyroberts.org.

14 Q So this e-mail address, if I understand you

15 correctly, is associated with these other domains?

16 A Correct.

17 MR. SYVERSON: We're on HHH.

18 (Exhibit HHH marked.)

19 BY MR. SYVERSON:

20 Q HHH is a December 10th, 2010, e-mail from

21 Michael Brown to yourself, amongst others.


23 A Yes, I am.


25 A This is an e-mail, as you mentioned, from

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247

1 Michael Brown to myself, Adam Zuckerman, Aaron

2 Thomas, Lori Wildrick, Ryan Page.

3 To put this in context, Michael Brown was

4 the one who was green-lighting, from a legal

5 perspective, when defamatory information could go

6 up. In this case, he was having us edit a defamatory

7 piece that was going to go up into the way that we

8 worded fraud.

9 Now, I'm not sure if it's a day or two

10 before or a day or two later, there will be another

11 e-mail where he tells us to, quote, "level Andrich,"

12 which is when the vinceandrich.net website came up.

13 Q And I believe that document has been entered

14 as an exhibit during Volume I of this deposition.

15 A And then the second part of this string is,

16 just as I had mentioned before, that Aaron Thomas was

17 the editor on everything that was defamatory; and

18 it's just that Aaron Thomas is apprising Adam

19 Zuckerman, myself, Michael Brown, Lori Wildrick, Ryan

20 Page that he fixed a number of typos and had the new

21 piece attached, which came up on steroid.com, which

22 is a website Adam worked at with somebody named Brian

23 Clapp to put up some defamatory pieces.

24 Q Does Adam Zuckerman have other involvement

25 with steroid.com other than this Anthony Roberts



248

1 piece?

2 A I believe that there was one that also came

3 up on Scott Connelly.

4 Q And if you know, who is in control -- strike

5 that.

6 Do you know who owns steroid.com?

7 A It was controlled by Anthony Roberts, but

8 Brian Clapp has a $5 million judgment against Anthony

9 Roberts. So he was able to go in and take control of

10 the site, and Brian allowed Adam to put some

11 defamatory information up online.

12 Q Where does Brian Clapp live, if you know?

13 A In Texas.

14 MR. SYVERSON: Why don't we take a break.

15 (Recess.)

16 MR. SYVERSON: So thank you for being here

17 today, Mr. Meade. That about does it. We're done

18 here today.

19 What will happen now is the court reporter

20 will take your testimony and prepare a transcript for

21 your review. The court reporter is -- probably most

22 efficient to have the court reporter mail it to you

23 with a self-addressed, stamped envelope to return

24 back to the court reporter.

25 Can you provide a return address to receive



249

1 that deposition transcript?

2 THE WITNESS: 22318 Third Avenue, Laguna

3 Beach, 92651.

4 MR. SYVERSON: And so what will happen is in

5 the mail you will receive a transcript of your

6 testimony here today and you will have 30 days from

7 the notice of that deposition transcript to provide

8 any corrections to your testimony here today. Of

9 course, if you do correct items, I can refer to that

10 at a later point.

11 If you do not return the transcript signed

12 and approved by yourself along with any changes, then

13 the transcript will simply become finalized.

14 In other words, if you don't get your

15 changes back to the reporter, then the transcript as

16 you've testified here today will become the final

17 transcript that we use at trial.

18 THE WITNESS: And what do we do -- I know I

19 sent the Volume I back and you had mentioned that it

20 hadn't made it back, so what do you do within the 30

21 day time frame if it's mailed back and it's

22 somehow --

23 MR. SYVERSON: We'll have to check -- do you

24 have copies of your Volume I changes?

25 THE WITNESS: Yes.



250

1 MR. SYVERSON: You've indicated that you

2 made Volume I changes.

3 THE WITNESS: Correct.

4 MR. SYVERSON: What we will have to do,

5 then, because I have not located in our office a copy

6 of your changes, you can resubmit those to my

7 office.

8 THE WITNESS: Okay.

9 MR. SYVERSON: And we can provide those to

10 the court reporter service that was used for

11 Volume I, which was a different court reporter

12 service than we used today -- if that makes any

13 sense.

14 THE WITNESS: Yeah. So I'll just get a card

15 on the way out to resend the changes that I have?

16 MR. SYVERSON: Correct.

17 THE WITNESS: Okay.

18 MR. SYVERSON: Do you have any further

19 questions?

20 THE WITNESS: No.

21 MR. SYVERSON: Okay. So 30 days to provide

22 corrections.

23 So stipulated.

24 THE WITNESS: Provided that they don't get

25 lost like the other ones did, because I think we're



251

1 about --

2 MR. SYVERSON: Okay, agreed.

3 (The deposition concluded at 1:59 p.m.)

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252

1 DECLARATION UNDER PENALTY OF PERJURY

2

3 I, Darren Mitchell Meade, do hereby certify

4 under penalty of perjury that I have read the

5 foregoing transcript of my deposition taken on

6 September 26, 2011; that I have made such corrections

7 as appear noted on the Deposition Errata Page,

8 attached hereto, signed by me; that my testimony as

9 contained herein, as corrected, is true and correct.

10

11 Dated this ________day of___________, 2011 at

12 _____________________, California.

13

14

15 ____________________________

16 Darren Mitchell Meade

17

18

19

20

21

22

23

24

25



253

1 DEPOSITION ERRATA SHEET

2 Page No._______ Line No._______

3 Change:______________________________________________

4 Reason for change:___________________________________

5 Page No._______ Line No._______

6 Change:______________________________________________


8 Page No._______ Line No._______

9 Change:______________________________________________


11 Page No._______ Line No._______

12 Change:______________________________________________


14 Page No._______ Line No._______

15 Change:______________________________________________


17 Page No._______ Line No._______

18 Change:______________________________________________


20 Page No._______ Line No._______

21 Change:______________________________________________


23

24 ________________________________ _________________

25 Darren Mitchell Meade Dated



254

1 STATE OF CALIFORNIA ) ) SS

2 COUNTY OF LOS ANGELES )

3

4 I, Terrie C. Barker, a Certified Shorthand

5 Reporter, do hereby certify:

6 That prior to being examined, the witness in the

7 foregoing proceedings was by me duly sworn to testify

8 to the truth, the whole truth, and nothing but the

9 truth;

10 That said proceedings were taken before me at

11 the time and place therein set forth and were taken

12 down by me in shorthand and thereafter transcribed

13 into typewriting under my direction and supervision;

14 I further certify that I am neither counsel for,

15 nor related to, any party to said proceedings, not in

16 anywise interested in the outcome thereof.

17 In witness whereof, I have hereunto subscribed

18 my name.

19

20 Dated: October 10, 2011

21

22

23 __________________________________ Terrie C. Barker

24 CSR No. 12000

25

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