Académique Documents
Professionnel Documents
Culture Documents
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)
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RICHARD ALLEN d/b/a VIRTUAL
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ACCOUNTING SERVICE, LLC;
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BETAFORCE NETWORKS, LLC;
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BLACKSEXFINDER CORP.; CHANEL
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FAULKNER d/b/a BLACKSEXFINDER; )
HARGRAY COMMUNICATIONS GROUP,)
INC.; M. BROWN BOOKS PUBLISHING )
)
GROUP, INC; MICHAEL, LAUDICK &
)
ASSOCIATES, LLC; DAVID MORGAN; )
PASSING LEADS, LLC; RIDE BEST, LLC; )
CURATORS OF THE UNIVERSITY OF
)
MISSOURI; and ERROL WILSON.
)
)
)
Defendants.
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TAMMY CONNELLY, and A. SCOTT
CONNELLY, M.D.,
Plaintiffs
vs.
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BOOKS PUBLISHING GROUP, INC; MICHAEL, LAUDICK & ASSOCIATES, LLC; DAVID
MORGAN; PASSING LEADS, LLC; RIDE BEST, LLC; CURATORS OF THE UNIVERSITY
PARTIES
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CONNELLY, M.D. (CONNELLY) are a married couple that live, and at all times relevant
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Service, LLC (ALLEN) is an individual that at all times relevant hereto resided in Sherman
Oaks, California.
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3.
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is a Florida limited liability company with its principal place of business in Pembrokes Pines,
Florida.
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place of business in Jacksonville, Florida. On information and belief, BSF, which was an adult
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2007.
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(BROWN BOOKS) is a Texas corporation having its principal place of business in Dallas,
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(HARGRAY) is a South Carolina corporation with its principal place of business in Hilton
Head, South Carolina. On information and belief, HARGRAY provides communications and
entertainment services to residential, business, large enterprise, and resort customers in South
Carolina and Georgia.
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Indiana LLC with its principal place of business in Indianapolis, Indiana. Defendant does
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(MIZZOU) is a body politic in which the state university is incorporated, which is governed by
a board of nine curators who are appointed by the Governor with the advice and consent of the
senate, with its principal place of business in Columbia, Missouri.
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individual that, at all times relevant hereto, resided in Claremore, Oklahoma doing business as
Davismor, Inc.
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is a Wisconsin limited liability company with its principal place of business in Green Bay,
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Wisconsin.
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Delaware corporation having its principal place of business in San Francisco, California. On
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information and belief, RIDE BEST d/b/a bestklothing.com and bestkiteboarding.com, sells kite
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that, at all times relevant hereto, resided in Port St. Lucie, Florida.
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This Court has original subject matter jurisdiction over the claims in this action
6 pursuant to 28 U.S.C. 1331 under the provisions of the Racketeer Influenced and Corrupt
7 Organizations Act, 18 U.S.C. 1961 et seq. and the Computer Fraud and Abuse Act. This Court
8 has jurisdiction over the claims in this action that arise under the law of the State of California
9 pursuant to 28 U.S.C. 1367(a), because the state law claims are so related to the federal claims
10 that they form part of the same case or controversy and derive from a common nucleus of operative
11 facts.
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Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b) because the
13 activities by the Defendants arose in, occurred within or were directed towards this jurisdiction;
14 and the damage sustained, occurred in the District.
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FACTUAL BACKGROUND
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A.
Overview
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This case is about reputation racketeering and the use of the internet to retaliate
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against individuals who step forward to bring online racketeers to justice by deploying defamatory
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websites, spam and malware attacks. This is a recent phenomenon which was given much
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attention in the recent prosecution and conviction of revenge porn operator Kevin Bollaert who
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soliciting victims to pay for the removal of such content through a bogus reputation management
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site.
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See People v. Kevin Christopher Bollaert, Case No. CD252338 (Cal Super. Ct. (SD Cty)
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punish anyone who steps forward. For example, in Commonwealth v Stephen Fustolo, Case No.
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1553CR001562 (Mass. Dist. Ct. (Middlesex Cty) July 14, 2015), the Massachusetts Attorney
General filed a complaint against a party who posted defamatory content on hundreds of blogs and
optimized the content for maximum impact in retaliation against a lender preceding on its claim
in bankruptcy. In doing so, one of Fustolos service providers explained that it is easier to ruin
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Both elements are present here and this action will depict a very real and growing
problem which poses a threat to our system of justice. As an Iowa prosecutor recently noted that
No greater threat to our criminal justice system exists than allowing convicted,
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incarcerated murderers (criminals), and their friends and family, to destroy the
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livelihoods and personal reputations of the people brave enough to testify against
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In Re Application for A Search Warrant for The Residence At 4221 155th Street,
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Urbandale, Iowa 50323 (Iowa Dist. Court (Sac Cty) July 9, 2014) (SAC COUNTY
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Warrant>.
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B.
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scheme the Federal Bureau of Investigation named Operation Lease Fleece" which caused more
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than $20 million in losses to several lending institutions that believed they were financing
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to the lenders. Instead, the money was used to make improper cash loans to the
small businesses and to pay lucrative commissions to employees at Capitalwerks,
Brickbanc and the other companies. Hundreds of bogus equipment-lease
packages with fake invoices were presented to financial institutions.
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Twenty-Three Charged In Leasing Fraud Scheme That Caused More Than $20 Million In Losses
To Lenders, Department of Justice Release No. 07-141 (Nov. 7, 2007)
<http://docslide.us/documents/07-official-lease-fleece-press-release.html>.
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release until 2012 when he was sentenced to thirty-seven (37) months in prison at the Federal
Correctional Institution at Terminal Island, San Pedro California. Under the terms of such
supervised release, ZUCKERMAN was to obey the law and not have any contact with the other
defendants.
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raise capital to bring the Progenex product to market. CONNELLY was referred to an investment
firm by the name of Mercury Ventures LLC and its wholly-owned subsidiary VenturePharma
LLC. ZUCKERMAN controlled both entities as Managing Director, albeit under the assumed
named of Adam Stuart, working with Operation Lease Fleece co-defendants Kirk McMahan and
Paul Arnold (both formerly of Brickbanc Capital) in violation of the terms of his supervised
release. ZUCKERMAN falsely represented that he had access to millions in investment capital
and could easily raise the seed capital needed for Progenex. As a result, in November 2009
CONNELLY, Murray Goulburn Nutritionals (Australia) and VenturePharma LLC agreed to set up
a new company to further develop the Progenex products that was to be financed by $4.0 million
in capital raised by VenturePharma and another $1 million from CONNELLY (which was to be
used solely for medical research).
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C.
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ZUCKERMAN seized control over the Progenex company and business assets from its inception
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in November 2009 and in February 2011 diverted Progenex funds to acquire rights to a new sort
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Grant Cooke (COOKE), which would enable the owner to turn off and deindex or restore pages
on third-party websites to public view. See Online reputation manager hacked websites to 'inject'
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attack on a database-driven Web site in which the attacker executes unauthorized SQL commands
by taking advantage of insecure code on a system connected to the Internet, bypassing the
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firewall. According to the Open Web Application Security Project, [a] successful SQL injection
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exploit can read sensitive data from the database, modify database data (Insert/Update/Delete),
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execute administration operations on the database (such as shutdown the DBMS), recover the
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content of a given file present on the DBMS file system and in some cases issue commands to the
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operating system.
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25.
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Borgia, entered into an exclusive license for use of THE COOL TECHNIQUE using Progenex
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funds. See Email Exchange Attached as Exhibit 2. He quickly began marketing it and made as
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C.
Targeting Connelly
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submission by tying him up in frivolous and vexatious litigation through a state court action for -
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CONNNELY refused to relent to Zuckermans actions and instead filed a cross-claim alleging
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fraud on the part of ZUCKERMAN and his associates. ZUCKERMAN, however, ultimately
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dismissed the action rather than comply with a court order to produce Progenexs bank records;
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smear campaign against CONNELLY in which he published websites using CONNELLYs name
WordPress and Tumblr sites) as well as others bearing the names of his associates to make
scandalous accusations against him involving fraud and sexual deviancy. A former Zuckerman
employee disclosed under oath that these tactics were designed to prevent public disclosure of
Zuckermans ongoing criminal activity while on supervised release and to coerce a settlement. To
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obtain the maximum impact, Zuckerman used Progenex funds to employ a team of people to
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optimize the smear sites for search engines so that it would rank among the first entries on search
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ZUCKERMANS behavior to the attention of law enforcement and regulatory agencies at the
D.
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CONNELLY estimates he received less than 6 unsolicited commercial emails (UCE) per week
at his BodyRx email address. Shortly after ZUCKERMAN was in custody, albeit with Internet
privileges, CONNELLYs level of spam emails began to increase exponentially to the point where
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on August 20, 2013 CONNELLY received 230 UCEs during a single 24 hour period and
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thereafter on average was receiving 350 UCEs per week during the period from September 2013
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For example, 39 of the 230 UCEs delivered on August 20, 2013 were exact copies
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of one another with each, upon examination, having links to malicious websites. In addition, five
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of the identical UCEs were routed through servers controlled by the United States government and
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foreign entities.
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Table 1
Email
From: skozak@headstrong.ie
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From: vera.hinson@cjharter.net
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Sent From
Routed Through
56.215.102.223
Raleigh, NC, United States
Provider: United States Postal
Service
123.27.94.35
Hanoi, Vietnam
RDNS: localhost
Provider: VietNam Post and
Telecom Corporation
132.62.24.71
Montgomery, AL, United
States
Provider: 754th Electronic
Systems Group
14.97.196.199
Mumbai, India
RDNS: static-199.196.97.14tataidc.co.in
Provider: TATA
TELESERVICES LTD - TATA
INDICOM - CDMA DIVISI
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From: iq5la@misys.ca
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From: spatel@begoro.com.ec
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55.212.115.198
Fort Huachuca, AZ, United
States
Provider: Headquarters,
USAISC
124.66.184.4
Seongnam, Korea, Republic of
Provider: SK C&C Co., Ltd.
152.80.166.27
Virginia Beach, VA, United
States
Provider: Navy Network
Information Center (NNIC)
2.184.215.18
Iran, Islamic Republic of
Provider: Information
Technology Company (ITC)
28.215.201.194
Columbus, OH, United States
Provider: DoD Network
Information Center
59.92.42.45
Chennai, India
Provider: NIB (National Internet
Backbone)
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From: sware@quadrem.com
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31.
On May 23, 2014, CONNELLY extinguished incoming email traffic access to his
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email account at BodyRx.com due to the volume of spam. The next day, MRS. CONNELLYS
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email account at Roadrunner.com received 25 UCEs over a single 12 hour period each bearing
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subject headers (e.g. medical billing and coding) duplicating hundreds of UCEs previously
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received by Dr. Connellys email at BodyRx.com. In the 15 years MRS. CONNELLY has owned
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this account she had never received this volume of UCE traffic in a single day, nor had she ever
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received any emails with the subject header medical billing and coding. Since that time MRS.
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CONNELLYS Roadrunner account has been receiving similar UCE traffic (as well as UCEs
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roadrunner.com remained free of atypical UCE traffic until August of 2014 when all 3 accounts
began receiving incremental numbers of UCEs with volumes reaching as many as 25 atypical
UCEs per day. The vast majority of these UCEs contained recurring subject headers denoting
salacious solicitations from female aliases and Russian pharmacy malware bearing attack
websites. Over 90% have contained links (URLS) delivering malicious code.
33.
The UCEs had many similar characteristics, demonstrating that this was a
coordinated attack, including, inter alia: (i) many were routed through common hosts but in
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innumerable cases were deployed in a similar manner using relay servers belonging to
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Center in Beijing, China, and the British government) and public and private universities in the
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United States and abroad (e.g. Florida State University, Massachusetts Institute of Technology,
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University of Missouri and the University of Limerick in Ireland); (ii) over 90 % used and/or were
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routed through domains that were newly registered on the day they were sent; and (iii) many e15
personated third parties ranging from governmental entities to established businesses including but
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not limited to Wells Fargo, Bank of America, Kohls, FedEX, PayPal, PG&E, Ray Ban, Facebook
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action on the part of CONNELLY, any effort on his part to indicate an awareness of the ongoing
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online racketeering, yielded a prompt spike in the level of UCE received within a matter of 24
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As the Sac County Iowa investigation into reputation racketeering gained public
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attention and the Sac County District Attorney Ben Smith (SMITH) reported his findings to
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ZUCKERMANS parole officer, nearly identical emails having links to malicious sites were also
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sent to SMITH and to John Gladych, CONNELLYs attorney in the Progenex dispute.
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deliver such email attacks and therefore relies on a network of hacker and cyber criminals who
provide templates for his email campaigns which they then either distribute via emails and/or host
the landing page for the link contained in the emails which usually contain malware. More
importantly, the emails are distributed to email accounts belonging to Plaintiffs that are not in
Figures 1A and 1B below illustrate this process, as Figure 1A is a January 16, 2016
sxybook.com and contains a link to landing page containing malware. Figure 1B is a similar
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February 24, 2016 UCE sent to CONNELLY at the same address but which reveals the existence
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Figure
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1A
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Figure
1B
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38.
Figure 2 illustrates how these email attacks are deployed. Figure 2A is an August
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4, 2015 UCE with the subject line 1 Pending Hot BOOty Call sent to CONNELLYS G-mail
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address inviting him to send a f#ck request. The email was sent from a Brazilian email address
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but a WHOIS search reveals that this domain is not registered and the routing path from the
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email header (as depicted in Figure 2B) reveals that it originated from brownchristianpress.com.
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Figure 2A
Figure 2B
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Figure 2A contains a link labeled view my profile here. This is a dynamic link in
that it continues to auto-update and redirect to different sites, presumably as the prior URL is shut
down for abuse. The link originally landed at nice-neighbors.org, but within a few days it
redirected to a new URL (hot-top-girls.com) with identical screen imagery and source code.
The
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link was still redirecting to updated versions (having the same source code and screen imagery)
40.
Exhibit 3 depicts the dynamic and international component of this campaign. The
UCE was sent to CONNELLYS non-public Yahoo! email address from Defendant PASSING
LEADS on or about October 7, 2015. On that day, the website redirected to Defendant BSF, but
by February 24, 2016 the website redirected to hot-top-a-juicyladies.org, a day old domain
41.
A substantial number of the UCEs received from September 2012 through to date
either contain pernicious malware as attachment or had links to malicious websites. Connelly had
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a portion of the UCE analyzed and discovered that they contained, inter alia, (i) the Zeus Trojan
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logging and form grabbing; (ii) Trojan.Fakeavlock which locks applications making the computer
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unusable and attempts to convince the user to purchase software in order to remove non-existent
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malware or security risks; (iii) Downloader.Upatre which is a Trojan horse that downloads
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potentially malicious files onto the compromised computer; (iv) Win32/Boaxxe.E which is a
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Trojan horse that drops Trojan:Win32/Boaxxe.F that installs itself as a browser helper object and
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may contact remote sites in order to download and execute arbitrary files; (v) Bladabindi which is
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a Trojan horse that steals confidential information from the compromised computer; (vi)
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Win32/Gamarue which is part of a family of malware that can download files and steal
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information about the compromised computer; and (vii) Downloader.Ponik which is a Trojan
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horse that downloads more malware onto the compromised computer and may also steal
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E.
Larger Defendants
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42.
CONNELLY has received over 100 UCEs promoting links to malicious content
hosted by BSF and/or FAULKNER starting in August 2015, including the following.
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Exhibit
Date
Ex. 4
8/15/15
Email Details
From: Margaret Garner
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10/7/15
Malware
Via Link
Via Link
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Ex. 5
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10/15/15
Via Link
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The UCEs improperly distributed a malicious link and were deceptive in terms of
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CONNELLY has received at least four UCEs promoting links to malicious content
hosted by HARGRAY. This includes the examples in Figure 1A and 1B and the following:
Exhibit
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Date
12/5/15
Ex. 6
Email Details
Malware
Via Link
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On information and belief, the routing information and links deployed in the
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The UCEs improperly distributed a malicious link and was deceptive in terms of
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Beginning in July 2015, CONNELLY has received at least 51 UCEs that originated
from MORGAN d/b/a Davismor, Inc. and whose links redirects to sweet-hookupgirls.com,
including the following:
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Exhibit
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12/5/15
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Ex. 7
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Date
Email Details
Malware
From: Laurena
To: Dr. Connelly Yahoo Account
Via Link
Re: hoooolaaaaaaa!!!
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The UCEs improperly distributed a malicious link and was deceptive in terms of
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CONNELLY has received three UCEs promoting links to malicious content hosted
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Exhibit
Date
4/21/15
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From: Paige
Malware
Via Link
Ex. 8
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Email Details
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On information and belief, the routing information and links deployed in the RIDE
BEST emails have similarities with an additional 25 UCEs that also redirect to get-laid-atnight.com.
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The UCEs improperly distributed a malicious link and were deceptive in terms of
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University Emails
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On information and belief, many of these educational institutions use Proofpoint, Inc. for email
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CONNELLY has received at least one UCE containing a malicious Trojan zip file
that originated from the University of Missouri and which used CONNELLYS bodyrx.com
domain as the sending address.
Exhibit
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Date
4/21/15
Ex. 9
Email Details
From: Administrator
Malware
Trojan Zip
File
To: info@bodyrx.com
Re: FW: Last Month Remit
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The UCE improperly delivered a Trojan zip file; was deceptive as to the sender and
its use of malware; and improperly e-personated CONNELLY by using the bodyrx.com domain.
Betaforce Networks, LLC
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examples of which are set forth below. In Exhibits 10 and 11, both emails e-personate actual
university employees at St. Cloud State University (Minnesota) and North Central State College
(Ohio) without their prior knowledge or consent. The emails were sent through internet protocol
10
Exhibit
11
Date
10/21/15
12
Email Details
From: Match.com
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Ex. 11
12/11/15
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To: [blank]
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Via Link
Ex. 10
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Malware
57.
n/a
Match.com; and were deceptive as to the sender and, in the case of Exhibit 10, its use of malicious
links.
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Smaller Defendants
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58.
CONNELLY received one UCE that originated from ALLEN on February 20,
2016 under the name Easy Kitty as set forth below that was routed through India and was
flagged by Gmail as a potential phishing email.
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Seconds later, CONNELLY received another Easy Kitty email that was sent
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from the same iPad but which originated in Uzbekistan and was routed through Ukraine,
demonstrating how the conspiracy is coordinated through multiple email accounts throughout the
world.
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Exhibit
Date
Email Details
Malware
6
2/20/16
Via Link
Ex. 12
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Re: Sup!8-)
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The email improperly distributed a malicious link and was deceptive in terms of the
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CONNELLY has received at least the one UCE depicted in Figure 2A from
The email improperly distributed a malicious link and was deceptive in terms of the
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63.
MRS. CONNELLY has received at least one UCE originating from MLA on
November 19 2015 that contained a link to a malicious site as set forth below.
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Exhibit
Date
Email Details
Malware
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11/19/15
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Ex. 13
From: Synergyshow
To: Mrs. Connelly
Via Link
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Re:
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64.
The email improperly distributed a malicious link and was deceptive in terms of the
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Erroll Wilson
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CONNELLY has received at least one UCE from WILSON that was routed
through United Kingdoms Ministry of Defence, as set forth below. The email is one of 135
UCEs CONNELLY has received that were routed through the Ministry of Defence.
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66.
Date
9/15/15
Ex. 14
10
Email Details
From: LOAN OFFER
Malware
n/a
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18 USC 1030
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Computer Fraud and Abuse Act (CFAA) 18 USC 1030(e), in that they are used in and affect
interstate commerce and communication.
69.
with an intent to defraud PLAINTIFFS via emails sent by DEFENDANTS containing malware or
links to malicious websites designed to access or damage PLAINTIFFS computer without their
knowledge and/or consent in violation of 18 USC 1030(a)(5)(A)
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during the last twelve months aggregating at least $5,000 in value in attempting to identify and
VIOLATIONS OF RACKETEER
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DEFENDANTS began working in concert for the purpose of punishing and harassing
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PLAINTIFFS to force CONNELLY to relent in his battles with ZUCKERMAN and his allies,
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with the transmission of unsolicited emails and malware being the weapon of choice.
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73.
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and therefore an enterprise, within the meaning of 18 U.S.C. 1961(5) and were engaged in, and
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its activities affected interstate and foreign commerce, within the meaning of Racketeer Influenced
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Each of the DEFENDANTS knew the essential nature and scope of the enterprise
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or enterprise(s) that he, she, or it was employed by or associated with, and each of the
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76.
The conduct of DEFENDANTS violated the law, inter alia, since it (i) is in
ZUCKERMANs illegal activities (18 U.S.C. 1513(b)); (ii) involved the sending of fraudulent
email to PLAINTIFFS by means of interstate wires (18 U.S.C. 1343); and (iii) violating
Californias Comprehensive Computer Data Access and Fraud Act (CCDAF) by transmitting
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PLAINTIFFS have been injured by, inter alia, having to spend money to
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commercial emails using a third party domain without permission; or which contain falsified,
misrepresented or forged header information; or that include deceptive subject lines. (Cal.
Business & Prof. Code 17529.5.)
80.
PLAINTIFFS have received over 3,000 UCEs from August 2014 to present most
For example, on August 4, 2015, CONNELLY received an email with the subject
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line 1 Pending Hot BOOty Call inviting him to send a fuck request. The email was sent from
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capelania@agricultursepp.ag.br but a WHOIS search reveals that this domain is not registered
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and the routing path was through brownbooks.com, a book publisher. (See Figure 2A.) This was
identical to dozens of emails he and MRS. CONNELLY had received using spoofed domains with
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separate routing information and deceptively promoting malicious websites as set forth above and
in the exhibits.
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83.
As a result of MIZZOUS conduct, PLAINTIFFS have suffered loss during the last
twelve months aggregating at least $5,000 in value in attempting to identify and remediate the
malware attacks by MIZZOU.
87.
MIZZOU acted willfully and with malice, fraud and/or oppression in transmitting
such malware.
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E-PERSONATION
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88.
The named Defendants have sent emails to CONNELLY using his name and/or
Such emails were sent knowingly and without consent of CONNELLY in violation
The named Defendants acted willfully and with malice, fraud and/or oppression in
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UNFAIR COMPETITION
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92.
committing illegal actions, including computer fraud as alleged above. DEFENDANTS have also
false information in their domain registrations so as to conceal their identities.
94.
The acts and conduct of DEFENDANTS constitute fraudulent, unlawful, and unfair
competition as defined by California Business & Professions Code Section 17200 et seq.
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28
24
95.
DEFENDANTS should be compelled to restore any and all money or property they
may have obtained in violation of California Business & Professions Code Section 17200 et seq.,
and should be enjoined from further unlawful, unfair and deceptive business practices.
NEGLIGENCE
8
9
10
96.
11
12
97.
15
13
14
98.
DEFENDANTS violated the duty of care owed to PLAINTIFFS and they have suffered damages
as a result.
16
17
//
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//
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1
2
3
1.
5
6
alleged herein;
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8
9
That this Court enter findings that the DEFENDANTS have engaged in the conduct
2.
and assigns, and persons, firms or corporations in active concert or participation with said
DEFENDANTS be immediately and permanently enjoined from engaging in such conduct;
10
3.
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12
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14
That PLAINTIFFS be awarded damages for the costs incurred in investigating and
4.
5.
That PLAINTIFFS be awarded damages under CASA of $1,000 for each UCE
seq.;
15
16
received;
17
18
6.
19
Section 528.5;
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21
7.
That PLAINTIFFS be awarded exemplary damages under CCDAF and Penal Code
That PLAINTIFFS recover its costs of this action together with reasonable
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8.
That the Court grant PLAINTIFFS such other and further relief as it deems just and
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1
2
JURY DEMAND
3
4
5
Pursuant to Federal Rule of Civil Procedure 38(b), PLAINTIFFS hereby demand a trial by
jury on all issues.
6
7
8
Respectfully submitted,
10
BY:
12
Bennet G. Kelley
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EXHIBIT 1
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv01255
Page E-1
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-2
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-3
FAC Exhibits
EXHIBIT 2
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Case No. 8:2015cv012
Page E-4
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-5
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-6
FAC Exhibits
EXHIBIT 3
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Case No. 8:2015cv012
Page E-7
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-8
FAC Exhibits
REDACTED
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-9
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-10
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-11
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-12
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-13
FAC Exhibits
EXHIBIT 4
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Case No. 8:2015cv012
Page E-14
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-15
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-16
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-17
FAC Exhibits
EXHIBIT 5
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Case No. 8:2015cv012
Page E-18
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-19
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-20
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-21
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-22
FAC Exhibits
EXHIBIT 6
Connelly v Doe
Case No. 8:2015cv012
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-23
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-24
FAC Exhibits
EXHIBIT 7
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-25
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-26
FAC Exhibits
EXHIBIT 8
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-27
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-28
FAC Exhibits
EXHIBIT 9
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-29
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-30
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-31
FAC Exhibits
EXHIBIT 10
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-32
FAC Exhibits
H3xFMM_QfS7aL0y3bmF558C8yKp7cIUzg3U2D7UpbU1tG6rJwa2iyJtPrtVP
Connelly v Doe
Case No. 8:2015cv012
Page E-33
FAC Exhibits
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Connelly v Doe
Case No. 8:2015cv012
Page E-35
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-36
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-37
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-38
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-39
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-40
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-41
FAC Exhibits
EXHIBIT 11
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-42
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-43
FAC Exhibits
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Connelly v Doe
Case No. 8:2015cv012
FAC Exhibits
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Subject: Hello Pretty
Connelly v Doe
Case No. 8:2015cv012
Page E-45
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-46
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-47
FAC Exhibits
EXHIBIT 12
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-48
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-49
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-50
FAC Exhibits
EXHIBIT 13
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv012
Page E-51
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-52
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-53
FAC Exhibits
REDACTED
Connelly v Doe
Case No. 8:2015cv012
Page E-54
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-55
FAC Exhibits
EXHIBIT 14
Connelly v Doe
Case No. 8:2015cv012
Page E-56
FAC Exhibits
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Case No. 8:2015cv012
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FAC Exhibits
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Connelly v Doe
Case No. 8:2015cv012
Page E-58
FAC Exhibits
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Connelly v Doe
Case No. 8:2015cv012
Page E-59
FAC Exhibits
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Connelly v Doe
Case No. 8:2015cv012
Page E-60
FAC Exhibits
Connelly v Doe
Case No. 8:2015cv012
Page E-61
FAC Exhibits