Case 8:12-ap-01550-ES Doc 98 Filed 02/21/17 Entered 02/21/17 23:23:31 Desc

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1 Anerio V. Altman, Esq. #228445

2 Lake Forest Bankruptcy
23151 Moulton Parkway Suite 131
3 Laguna Hills, CA 92653
4 Phone and Fax: (949) 218-2002
avaesq@lakeforestbkoffice.com
5
6
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9 UNITED STATES BANKRUPTCY COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
SANTA ANA DIVISION
12
13 In re: ) Case No.: 8:12-BK-17907-ES
)
14 JAY PHOTOGLOU, )
) Chapter 7
15 )
Debtor. )
16 ) Adversary No. 8:12-AP-1550-ES
)
17 GRETCHEN ROSSI, )
) TRIAL DECLARATION OF
18 Plaintiff, ) HAKOP JACK KETSOYAN
)
19 ) TRIAL:
vs. )
20 ) Date: March 22nd, 2017
JAY PHOTOGLOU, ) Time: 9:00 A.M.
21 )
) Place: Courtroom 5A
Defendant.
22 )
)
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________________________________________________________________________________

TRIAL DECLARATION
Case 8:12-ap-01550-ES Doc 98 Filed 02/21/17 Entered 02/21/17 23:23:31 Desc
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1
2 I, HAKOP JACK KETSOYAN, declare as follows:
3
1. I am over the age of 18 years old and I am legally able and competent to
4
5 testify to the following in a court of law.
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2. I have known and worked with Plaintiff Gretchen Rossi (Rossi) since
7
8 February 10th, 2009 in the capacity as her public relations specialist and

9 appearance manager.
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3. I have worked in this industry for almost two decades. Through my
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12 corporations, my clients have included numerous well known celebrities
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such as Paris Hilton, Carmen Electra, AOL Westfield Shopping Center,
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15 Kristin Cavallari and many others.

16 4. I am familiar with the customs and practices related to the management of a

17
celebrity personality in todays media marketplace.
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19 5. I have personally had to deal with all the negative and false claims made
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about Rossi by Defendant Jay Photoglou (Photoglou) through 2009 and
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22 2010.

23 6. These claims included assertions that he was Rossis secret boyfriend,

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that he lived with Rossi from December 2008 through February 2009, and
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26 that Rossis engagement to Mr. Jeff Beitzel was fake.
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28

1
______________________________________________________________________
DECLARATION
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1 7. Photoglous actions and attempts to assassinate Rossis character have

2 resulted in the loss of appearances, endorsement contracts and revenue

3
generating opportunities. The loss of revenue opportunities for Rossi stem
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5 from Photoglous numerous blog posts; TV Interviews, document posts to
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www.whatsleftofmyhead.com as well as the photos leaked to
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8 www.thedirty.com and numerous other websites claiming Photos courtesy

9 of Jay Photoglou.
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8. For example, I am aware of an article that was posted on February 20th,
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12 2010 by Seacost Online, a true and correct copy of which is attached hereto,
13
in which they claimed to have received an email from Jay Photoglou.
14
15 Attachment A.

16 9. Rossi has spent thousands of dollars with my company alone having to deal
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with Photoglous actions. When pitching or promoting Rossi for hosting
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19 work or appearances, I found that companies declined wanting to work with
20
Rossi due to the accusations being made about her by Photoglou. They
21
22 refuse to have their company or brand associated with a scandal that was

23 being circulated by Photoglou, who was calling and making claims to the
24
press and news organizations in an attempt to get his name in the media.
25
26 10. I believe that as a result of the actions of Photoglou, Rossi lost an
27
opportunity to continue with the Real Housewives of OC. At the time of
28

2
______________________________________________________________________
DECLARATION
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ATTACHMENT A
'Real Housewives': Man8:12-ap-01550-ES
Gretchen reportedly cheated with98
speaks out
http://www.seacoastonline.com/article/20090224/ENTERTAIN/90...
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ON DEMAND
RADIO: (http://edgeradio.streamon.fm)
(HTTPS://OMNY.FM/SHOWS/EDGERADIOONDEMAND)
(http://www.edgeradio.com
(http://edgeradio.streamon.fm) (http://www.loonmtn.com
)

'Real Housewives': Man Gretchen reportedly

cheated with speaks out

Tuesday
Posted Feb24,2009at10:45PM

The man Tamra Barney accused Gretchen Rossi of dating

while still engaged to her fianc -- who has since died of
leukemia -- is sending an e-mail around to tell his side of
the story.

By Gina Carbone The man Tamra Barney accused Gretchen Rossi of dating
while still engaged to her fianc -- who has since died of leukemia -- is sending
an e-mail around to tell his side of the story.

Tamra and Gretchen who've alternated between fighting and bonding

throughout season four of "The Real Housewives of Orange County" finally
had it out Tuesday on "The Real Housewives Confess: A Watch What Happens
Special."

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Gretchen reportedly cheated with98
speaks out
http://www.seacoastonline.com/article/20090224/ENTERTAIN/90...
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The housewivesONfrom OC
DEMAND sat down with host Andy (http://edgeradio.streamon.fm)
RADIO: Cohen, who does not pull
(HTTPS://OMNY.FM/SHOWS/EDGERADIOONDEMAND)
any punches,(http://edgeradio.streamon.fm)
bless him.
(http://www.edgeradio.com (http://www.loonmtn.com
)
On the left side of the set: Vicki Gunvalson and Tamra.

To Andy's right: Jeana Keough, Gretchen and Lynne Curtin. Later in the
evening, very briefly, Lauri Waring showed up to sit next to Vicki and talk about
her son, Josh, who should be getting out of jail soon.

I'm fond of the moment when Gretchen said she didn't know who Florence
Nightingale was, never mind "All About Eve" "Is that Adam and Eve?" -- but
the most dramatic part of the night was still another throwdown between the
two hottest housewives.

They showed the clip where Tamra said she felt Gretchen and her now deceased
fianc Jeff had a relationship of convenience.

Andy asked what made her think that.

There was stuff going on behind the scenes, Tamra said, to make her think that.

For example, about 1 a.m. the night before they went to Del Mar, her cell phone
rang. A guy asked "Can I speak to Tamra please?"

She asked who it was. It's Gretchen's boyfriend, the guy told her. "Tamra, this is
Jay."

He told Tamra that Gretchen dumped him by the side of the road at 1 a.m. He
wanted Tamra to have Gretchen come get him or he would basically out their
relationship.

Jay told Tamra and her husband Simon that he had been dating Gretchen for a
long time and that Jeff was paying Gretchen to take care of him.

Tamra later got a call from Gretchen where Gretchen said Jay was an old
boyfriend, now a stalker.

How did Gretchen end up out with this guy? She was at a party with mutual
friends, she explains. She offered to drive him home. He tried to make a move on
her, she refused and told him to get out of the car.

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http://www.seacoastonline.com/article/20090224/ENTERTAIN/90...
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But this guy kept
ONcalling,
DEMAND Tamra
RADIO: said. (http://edgeradio.streamon.fm)
(HTTPS://OMNY.FM/SHOWS/EDGERADIOONDEMAND)
(http://www.edgeradio.com
(http://edgeradio.streamon.fm) (http://www.loonmtn.com
Gretchen
) said she's not dating Jay now.

Tamra asked if he was with her at Bass Lake.

Gretchen said yes. "My family was there! He's a family friend!"

Tamra: "I thought you said he was a stalker."

They call each other liars.

Jeana asked what does it matter if Gretchen is dating the guy?

Tamra: "It's about moral character."

HAHAHAHAHAHAHA

Gretchen asked if it's the same moral character that had Tamra get her "naked
wasted" and sicked Ryan on her.

Tamra: "You're such a f---ing victim, aren't you."

Gretchen: "Do you really hate me that much?"

Tamra said Jeana said the guy's clothes were on Gretchen's bedroom floor.
Gretchen wants to know when they were even in her room. Jeana said they were
all in the room and the clothes were there.

Andy wanted a final ruling from Gretchen: "You are single right now?"

Gretchen: "Yes."

Andy: "This man who has been calling Tamra is not your boyfriend?"

Gretchen said no.

Vicki: "Do you sleep with him?"

Gretchen: "No." Interestingly enough, on Friday, Feb. 20 a guy named Jay

Photoglou sent me (and everyone else who has ever written about "The Real
Housewives," I'm sure) an e-mail, preparing the world for this TV moment.

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http://www.seacoastonline.com/article/20090224/ENTERTAIN/90...
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"I am Jay Photoglou. I will
ON DEMAND be brought up by the cast(http://edgeradio.streamon.fm)
RADIO: of the Real Housewives of
(HTTPS://OMNY.FM/SHOWS/EDGERADIOONDEMAND)
OC on the reunion
(http://www.edgeradio.com show set to aire Feb 24th. I have a picture (several) of
(http://edgeradio.streamon.fm) (http://www.loonmtn.com
matching
) tattoo's (on our ring finger) Gretchen and I got in Oct to show our
love to each other. We have been together for over a year and she has now let
the fame of the show be more important than us being together. I have alot more
information on this but need to make sure it is out before the reunion show. I
AM WILLING TO TAKE A LIE DETECTOR TEST. I also lived with Gretchen
and still have MOST of my stuff at her house. I refuse to go get it because Slade
Smiley is staying with her. I would like my full story told before the reunion
show."

He attached two photos one dated New Year's 2008-2009 with the two of them
kissing.

He also shared two links to other stories on Gretchen:

Story on Gretchen in National Enquirer: "HOUSEWIVES STAR CHEATED

ON DYING FIANCE."

Story on Gretchen in Daily Pilot: "Beauty pageant turns ugly: Celebrity

slated to host annual event is dropped after flood of negative opinions
about actions on reality TV show".

I did not contact him before the reunion show and I don't plan on tracking him
down now. This isn't exactly Watergate and it looks like both sides are going to
keep playing the same game.

It's like Gretchen said of the thin line between sexy and skanky. I'm not going to
pretend even spending this much time on a domestic dispute is classy but I'm
also not going to pull a Tamra and do moral grandstanding. They can work it
out.

My real question is: Now that Gretchen is even less of a housewife, will return
for season five? Should she?

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Gretchen reportedly cheated with98
speaks out
http://www.seacoastonline.com/article/20090224/ENTERTAIN/90...
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ON DEMAND
RADIO: (http://edgeradio.streamon.fm)
(HTTPS://OMNY.FM/SHOWS/EDGERADIOONDEMAND)
(http://www.edgeradio.com
(http://edgeradio.streamon.fm) (http://www.loonmtn.com
)

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