Plaintiff's 1st Set of Interrogatories For Reality Steve LLC & Steve Carbone

Case 2:11-cv-10118-GHK-E Document 29-1
Filed 03/26/12 Page 1 of 74 Page ID #:231
EXHIBIT A TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT A TO DECLARATION OF ANDREW W. DeFRANCIS
Case 2:11-cv-10118-GHK-E Document 29-1 Filed 01/31/12 Page 12 of2 Page ID ID #:232 Cas 2:11-cv-10118-GHK-E Document 21 Filed 03/26/12 Page of 74 Page #:164
1 2 3 4 5 6 7
FILED: 1/31/12
NOTE: CHANGES MADE BY THE COURT
8
9 10 11 12 NZK PRODUCTIONS INC., a California corporation, and HORIZON 13 ALTERNATIVE TELEVISION INC., a Delaware corporation, 14 Plaintiffs, 15 V. 16 STEPHEN CARBONE, an individual, 17 REALITY STEVE, LLC, a Texas limited liability corporation, and DOES 18 1 through 10, inclusive, 19 20 21 22 23 24 25 26 27 28
298107.1.doc
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
CASE NO. CV11-10118 GHK (Ex)
Defendants.
[PROPOSED] ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION (1) TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO DISMISS BY 60 DAYS TO PERMIT JURISDICTIONAL DISCOVERY, AND (2) FOR AN ORDER PERMITTING PLAINTIFFS TO CONDUCT SUCH DISCOVERY; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
Exhibit A Page 4
CV11-10118 GHK (Ex) [PROPOSED] ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION (1) TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO DISMISS, AND (21 FOR AN ORDER PERMITTING PLAINTIFFS TO CONDUCT SUCH DISCOVERY
Case 2:11-cv-10118-GHK-E Document 29-1 Filed 01/31/12 Page 23 of2 Page ID ID #:233 Cas 2:11-cv-10118-GHK-E Document 21 Filed 03/26/12 Page of 74 Page #:165
The Court has reviewed Plaintiffs NZK Productions Inc. and Horizon
2 Alternative Television Inc. (collectively, "Plaintiffs") ex parte application 3 ("Application") (1) to continue the hearing date on the motion to dismiss filed by 4 Defendants Stephen Carbone and Reality Steve, LLC (collectively, "Defendants") 5 by sixty (60) days so that Plaintiffs may conduct jurisdictional discovery, and (2) for 6 an order permitting Plaintiffs to conduct said jurisdictional discovery. Defendants 7 have filed no opposition. Having found good cause, 8 9 IT IS HEREBY ORDERED that Plaintiffs' Application is GRANTED. The hearing date on Defendants' Motion to Dismiss for Lack of Personal
10 Jurisdiction shall be continued from March 12, 2012, at 9:30 a.m., to 11 12 May 20
, 2012, at 9:30 a.m.
In the interim, Plaintiffs are hereby permitted leave of Court to conduct
13 written and oral jurisdictional discovery, including but not limited to, noticing 14 depositions of both Defendants, propounding interrogatories, requests for admission, 15 and requests for production, and serving subpoenas on relevant third parties for the 16 purposes of determining Defendants' connection with California. 17 18 Dated this 31 st day of Jan 19 20 21 22 23 24 25 26 27 28
298107.1.doc
, 2012.
By Hon. George H
Exhibit A Page 5
[PROPOSED] ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION (1) TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO DISMISS, AND (2) FOR AN ORDER PERMITTING PLAINTIFFS TO CONDUCT SUCH DISCOVERY
CV11-10118 GHK (Ex)
EXHIBIT B TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT B TO DECLARATION OF ANDREW W. DeFRANCIS
1 KELLEY DRYE & WARREN LLP Michael J. O'Connor (STATE BAR NO. 90017) 2 Andrew W. DeFrancis (STATE BAR NO. 246399) 10100 Santa Monica Boulevard, Twenty-Third Floor Los Angeles, California 90067-4008 3 Telephone: 310) 712-6100 Facsimile: 10) 712-6199 4 moconnor kelleydrye.corn 5 adefrancis kelleydrye.corn 6 Attorneys for Plaintiffs NZK PRODUCTIONS INC. and 7 HORIZON ALTERNATIVE TELEVISION INC. 8 9 10 11 NZK PRODUCTIONS INC., a 13 California corporation, and HORIZON ALTERNATIVE TELEVISION INC., a 14 Delaware corporation, 15 16 v. Plaintiffs, 12 CASE NO. CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
17 STEPHEN CARBONE, an individual, REALITY STEVE, LLC, a Texas 18 limited liability corporation, and DOES 1 through 10, inclusive, 19 Defendants. 20 21 22 23 24 PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC. 25 RESPONDING PARTY: 26 SET NO.: 27 28
298408. I .doc
DEFENDANT STEPHEN CARBONE ONE

Exhibit B Page 6
CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that, pursuant to Rule 33 of the Federal Rules of
3 Civil Procedure and Local Rule 33-2 of the United States District Court for the 4 Central District of California, Defendant Stephen Carbone is directed to answer in 5 writing and under oath each of the following interrogatories propounded by Plaintiff 6 NZK Productions Inc. ("Interrogatories"), within the time provided by Rule 33. 7
SPECIAL INTERROGATORIES
IDENTIFY all PERSONS who contacted YOU at steve@realitysteve.com
8 SPECIAL INTERROGATORY NO. 1: 9 10 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 11 The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as to 12 an individual, stating his or her full and customarily used names, present resident 13 address, business address, and business telephone number; (b) as to any person other 14 than an individual, stating its legal name and any other names used by it, the form or 15 manner of its organization (e.g., partnership, corporation, etc.), the state of its 16 incorporation (if it is incorporated) or the state of its formation (if it is a partnership 17 or limited liability company), and the address of its principal place of business; 18 (c) as to any document, its author, recipient, sender, date(s), its subject matter, the 19 number of pages therein, and wherever possible its corresponding BATES 20 number(s); and (d) as to an event, transaction, or occurrence stating its date, the 21 location and the manner of its occurrence (e.g., face-to-face meeting of participants, 22 telephone calls, etc.), the identification of all its participants and eyewitnesses to its 23 occurrence, its purpose and subject matter, a concise description of what transpired, 24 and IDENTIFY any document referring to or concerning said event, transaction, or 25 occurrence. 26 The terms "PERSON" and "PERSONS," as used in these Interrogatories,
27 shall mean all natural persons, partnerships, consortia, joint ventures, and every Exhibit B Page 7 28 other form of legally recognized entity, including corporations.
298408.1 doc
CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE
The terms "YOU" and "YOUR," as used in these Interrogatories, shall mean
2 Defendant Stephen Carbone, acting in his individual capacity or as an agent of 3 Defendant Reality Steve, LLC. 4 The term "THE BACHELOR SERIES," as used in these Interrogatories, shall
5 mean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad" television 6 series. 7 SPECIAL INTERROGATORY NO. 2: 8 State the date(s) that each PERSON identified in response to Special
9 Interrogatory No. 1 contacted YOU. 10 SPECIAL INTERROGATORY NO. 3: 11 IDENTIFY all PERSONS who YOU contacted from steve@realitysteve.com 12 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 13 SPECIAL INTERROGATORY NO. 4: 14 State the date(s) that YOU contacted each PERSON identified in response to
15 Special Interrogatory No. 3. 16 SPECIAL INTERROGATORY NO. 5: 17 IDENTIFY all PERSONS who contacted YOU at twitter.com/realitysteve 18 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 19 SPECIAL INTERROGATORY NO. 6: 20 State the date(s) that each PERSON identified in response to Special
21 Interrogatory No. 5 contacted YOU. 22 SPECIAL INTERROGATORY NO. 7: 23 IDENTIFY all PERSONS who YOU contacted from twitter.com/realitysteve 24 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 25 SPECIAL INTERROGATORY NO. 8: 26 28
298408.I.doc
State the date(s) that YOU contacted each PERSON identified in response to
Exhibit B Page 8
PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE
27 Special Interrogatory No. 7.
CV11-10118 GHK (Ex)
1 SPECIAL INTERROGATORY NO. 9: 2 IDENTIFY each public appearance that YOU made to promote 3 www.realitysteve.com between January 1, 2004, and the present. 4 SPECIAL INTERROGATORY NO. 10: 5 IDENTIFY each INTERVIEW YOU gave concerning THE BACHELOR 6 SERIES between January 1, 2004, and the present. 7 The term "INTERVIEW," as used in these Interrogatories, shall mean any
8 type of media appearance, including but not limited to television, radio, print, or 9 other type of media appearance. 10 SPECIAL INTERROGATORY NO. 11: 11 IDENTIFY each ARTICLE that YOU authored concerning THE
12 BACHELOR SERIES between January 1, 2004, and the present. 13 The term "ARTICLE," as used in these Interrogatories, shall mean any
14 writing that appears on the internet, in an email or print newsletter, in a newspaper, 15 in a magazine, or in any other print publication. 16 SPECIAL INTERROGATORY NO. 12: 17 IDENTIFY each PERSON from whom YOU received any information
18 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 19 SPECIAL INTERROGATORY NO. 13: 20 21 For each of the PERSONS identified in response to Special Interrogatory No. 12, state the date(s) each PERSON provided YOU with information about THE
22 BACHELOR SERIES. 23 SPECIAL INTERROGATORY NO. 14: 24 IDENTIFY all communications that YOU initiated with any PERSON who is 25 or was a resident of California concerning THE BACHELOR SERIES. 26 SPECIAL INTERROGATORY NO. 15: 27 IDENTIFY all communications that YOU initiated with any PERSON who is
CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES Exhibit B TO DEFENDANT STEPHEN CARBONE
28 or was a resident of California concerning www.realitysteve.com 298408. I .doc 3
Page 9
1 SPECIAL INTERROGATORY NO. 16: 2 IDENTIFY all communications that YOU received from any PERSON who 3 is or was a resident of California concerning THE BACHELOR SERIES. 4 SPECIAL INTERROGATORY NO. 17: 5 IDENTIFY all communications that YOU received from any PERSON who
6 is or was a resident of California concerning www.realitysteve.com 7 SPECIAL INTERROGATORY NO. 18: 8 IDENTIFY all trips that YOU made to California between January 1, 2004, 9 and the present. 10 SPECIAL INTERROGATORY NO. 19: 11 For each of the trips identified in response to Special Interrogatory No. 18,
12 IDENTIFY where you stayed while visiting California. 13 SPECIAL INTERROGATORY NO. 20: 14 Describe the purpose of each of the trips identified in response to Special 15 Interrogatory No. 18. 16 SPECIAL INTERROGATORY NO. 21: 17 IDENTIFY all real estate that YOU own in California, including any real
18 estate that you jointly own with another PERSON. 19 SPECIAL INTERROGATORY NO. 22: 20 IDENTIFY all bank accounts that YOU own or control in California.
21 SPECIAL INTERROGATORY NO. 23: 22 IDENTIFY all sources of income that YOU derive from California, including
23 all income derived from PERSONS who reside in California. 24 SPECIAL INTERROGATORY NO. 24: 25 IDENTIFY each time that YOU paid income taxes in California between Exhibit B
Page 10
298408.1.doc
26 January 1, 2004, and the present. 27 / / / 28
CV11-10118 GHK (Ex) 4 PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARB ONE
1 SPECIAL INTERROGATORY NO. 25: 2 IDENTIFY each time that YOU voted in an ELECTION as a California
3 resident between January 1, 2004, and the present. 4 The term "ELECTION", as used in these Interrogatories, shall mean any type
5 of political election, including local, statewide, and national elections. 6 7 DATED: February 7, 2012 KELLEY DRYE & WARREN Michael J. O'Connor Andrew W. DeFrancis
LLP
8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
298408. I .doc
By C:4!g2 Andrew W. Francis Attorneys for Plain s NZK Productions Inc. and Horizon Alternative Television Inc.
Th
Exhibit B Page 11
PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE
CV11-10118 GHK (Ex)
PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles, State of California. My 4 business address is 10100 Santa Monica Boulevard, Twenty-Third Floor, Los Angeles, California 90067. 5 On February 7, 2012, I served a true copy of the foregoing document . 6 described as PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE 7 on the interested parties in this action as follows: 3 8 9 10 11 12 BY FEDERAL EXPRESS: I enclosed said document in an envelope or 14 package provided by Federal Express and addressed to the persons at the addresses listed in the Service List. I_placed the envelope or package for collection and 15 overnight delivery at an office or a regularly utilized drop box of Federal Express or delivered such document to a courier or driver authorized by Federal Express to 16 receive documents. FEDERAL: I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am 18 employed in the office of a member of the bar of this Court at whose direction the service was made. 19 Executed on February 7, 2012, at Los Angeles, California. 20 17 21 22 23 24 25 26 27 28
298408.! .doc
D. Bradley Kizzia, Esq. Brown Fox Kizzia & Johnson PLLC 8226 Douglas Avenue, Suite 411 Dallas, TX 75225 Fax: 214-613-3330 brad@brownfoxlaw.com Attorneys for defendants Stephen Carbone and Reality Steve, LLC
Gregg A. Farley, Esq. Law Offices of Gregg A. Farley 11755 Wilshire Boulevard, Suite 1845 Los Angeles, CA 90025 Fax: 310-445-4109 gfarley@farleyfirm.com Attorneys for defendants Stephen Carbone and Reality Steve, LLC
13
Exhibit B Page 12
CV11-10118GHK (Ex) 6 PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT STEPHEN CARBONE
EXHIBIT C TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT C TO DECLARATION OF ANDREW W. DeFRANCIS
1 KELLEY DRYE & WARREN LLP Michael J. O'Connor (STATE BAR NO. 90017) 2 Andrew W. DeFrancis (STATE BAR NO. 246399) 10100 Santa Monica Boulevard, Twenty-Third Floor 3 Los Angeles California 90067-4008 Telephone: 310) 712-6100 4 Facsimile: 10) 712-6199 moconnor kelleydrye.corn 5 adefrancis kelleydrye.corn 6 Attorneys for Plaintiffs NZK PRODUCTIONS INC. and 7 HORIZON ALTERNATIVE TELEVISION INC. 8 9 10 11 NZK PRODUCTIONS INC., a 13 California corporation, and HORIZON ALTERNATIVE TELEVISION INC., a 14 Delaware corporation, 15 16 V. Plaintiffs, 12 CASE NO. CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
17 STEPHEN CARBONE, an individual, REALITY STEVE, LLC, a Texas 18 limited liability corporation, and DOES 1 through 10, inclusive, 19 Defendants. 20 21 22 23 24 PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC. 25 RESPONDING PARTY: 26 SET NO.: 27 28
298409.1.doc
DEFENDANT REALITY STEVE, LLC ONE

Exhibit C Page 13
CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC
1 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that, pursuant to Rule 33 of the Federal Rules of
3 Civil Procedure and Local Rule 33-2 of the United States District Court for the 4 Central District of California, Defendant Reality Steve, LLC is directed to answer in 5 writing and under oath each of the following interrogatories propounded by Plaintiff 6 NZK Productions Inc. (the "Interrogatories"), within the time provided by Rule 33. 7
SPECIAL INTERROGATORIES
IDENTIFY each PERSON with whom YOU registered
8 SPECIAL INTERROGATORY NO. 1: 9 10 www.realitysteve.com between January 1, 2004, and the present. 11 The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as to
12 an individual, stating his or her full and customarily used names, present resident 13 address, business address, and business telephone number; (b) as to any person other 14 than an individual, stating its legal name and any other names used by it, the form or 15 manner of its organization (e.g., partnership, corporation, etc.), the state of its 16 incorporation (if it is incorporated) or the state of its formation (if it is a partnership 17 or limited liability company), and the address of its principal place of business; 18 (c) as to any document, its author, recipient, sender, date(s), its subject matter, the 19 number of pages therein, and wherever possible its corresponding BATES 20 number(s); and (d) as to an event, transaction, or occurrence stating its date, the 21 location and the manner of its occurrence (e.g., face-to-face meeting of participants, 22 telephone calls, etc.), the identification of all its participants and eyewitnesses to its 23 occurrence, its purpose and subject matter, a concise description of what transpired, 24 and IDENTIFY any document referring to or concerning said event, transaction, or 25 occurrence. 26 The terms "PERSON" and "PERSONS," as used in these Interrogatories, 27 shall mean all natural persons, partnerships, consortia, joint ventures, and every Exhibit C Page 14 28 other form of legally recognized entity, including corporations.
298409 1 doc
CV1I-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC
The terms "YOU," "YOUR," or "DEFENDANT," as used in these
2 Interrogatories, shall mean Defendant Reality Steve, LLC and each of its past and 3 present agents, associates, managers, representatives, accountants, attorneys, and 4 anyone else acting, or who has acted, on its behalf, including Defendant Stephen 5 Carbone. 6 SPECIAL INTERROGATORY NO. 2: 7 State the date(s) YOU registered www.realitysteve.com with each of the 8 PERSONS identified in response to Special Interrogatory No. 1. 9 SPECIAL INTERROGATORY NO. 3: 10 IDENTIFY each PERSON who HOSTED www.realitysteve.com between
11 January 1, 2004, and the present. 12 The term "HOSTED," as used in these Interrogatories, shall mean the act of 13 providing server space, internet services, and/or file maintenance for websites. 14 SPECIAL INTERROGATORY NO. 4: 15 State the date(s) that each PERSON identified in response to Special 16 Interrogatory No. 3 HOSTED www.realitysteve.com . 17 SPECIAL INTERROGATORY NO. 5: 18 IDENTIFY all agreements of any kind entered into between January 1, 2004, 19 and the present concerning advertising on www.realitysteve.com . 20 SPECIAL INTERROGATORY NO. 6: 21 IDENTIFY all PERSONS who have purchased advertising on
22 www.realityseteve.com between January 1, 2004, and the present. 23 SPECIAL INTERROGATORY NO. 7: 24 State all username accounts registered on www.realitysteve.com .
25 SPECIAL INTERROGATORY NO. 8: 26 For each of the username accounts identified in response to Special
Exhibit C Page 15
298409.1.doc
27 Interrogatory No. 7, state the email address affiliated with each account. 28
CV11-10118 GHK (Ex) 2 PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC
1 SPECIAL INTERROGATORY NO. 9: 2 IDENTIFY all PERSONS who have a contractual relationship of any kind 3 with www.realitysteve.com . 4 SPECIAL INTERROGATORY NO. 10: 5 Describe YOUR contractual relationship with each PERSON identified in 6 response to Special Interrogatory No. 9. 7 SPECIAL INTERROGATORY NO. 11: 8 IDENTIFY all members of Reality Steve, LLC from January 1, 2004, through
9 the present. 10 SPECIAL INTERROGATORY NO. 12: 11 For each of the PERSONS identified in response to Special Interrogatory No. 12 11, state the date(s) each PERSON was a member of Reality Steve, LLC. 13 SPECIAL INTERROGATORY NO. 13: 14 State the monthly number of visitors to www.realitysteve.com between
15 January 1, 2004, and the present. 16 SPECIAL INTERROGATORY NO. 14: 17 State the monthly number of visits to www.realitysteve.com by PERSONS 18 located in California between January 1, 2004, and the present. 19 SPECIAL INTERROGATORY NO. 15: 20 State the monthly number of visits to www.realitysteve.com by computers 21 located in California between January 1, 2004, and the present. 22 SPECIAL INTERROGATORY NO. 16: 23 IDENTIFY all bank accounts that YOU own or control in California. 24 SPECIAL INTERROGATORY NO. 17: 25 IDENTIFY all sources of income that YOU derive from California, including
26 all income derived from PERSONS who reside in California. 27 / / / 28

///
298409.1.doc
Exhibit C Page 16
CV11-10118 GHK (Ex) PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC
1 SPECIAL INTERROGATORY NO. 18: 2 IDENTIFY each time that YOU paid income taxes in California between 3 January 1, 2004, and the present. 4 SPECIAL INTERROGATORY NO. 19: 5 IDENTIFY all trips to California made on behalf of YOU between January 1, 6 2004, and the present. 7 SPECIAL INTERROGATORY NO. 20: 8 Describe the purpose of each of the trips identified in response to Special 9 Interrogatory No. 19. 10 SPECIAL INTERROGATORY NO. 21: 11 IDENTIFY each PERSON from whom YOU received any information
12 concerning THE BACHELOR SERIES between January 1, 2004, and the present. 13 The term "THE BACHELOR SERIES," as used in these Interrogatories, shall
14 mean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad" television 15 series. 16 SPECIAL INTERROGATORY NO. 22: 17 For each of the PERSONS identified in response to Special Interrogatory No.
18 21, state the date(s) that each PERSON provided YOU with information about THE 19 BACHELOR SERIES. 20 SPECIAL INTERROGATORY NO. 23: 21 IDENTIFY each public appearance that YOU made to promote 22 www.realitysteve.com between January 1, 2004, and the present. 23 SPECIAL INTERROGATORY NO. 24: 24 IDENTIFY each member of YOUR member Yea! Network, LLC, as 25 identified at page 7 of YOUR MOTION TO DISMISS. 26 The term "MOTION TO DISMISS," as used in these Interrogatories, shall
Exhibit
27 mean Defendants Stephen Carbone and Reality Steve, LLC's Motion to Dismiss for 28 Lack of Personal Jurisdiction in this matter, filed on January 20, 2012. 298409 1.doc CV11-10118 GHI13 aEx ) 17 C( e 4
PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC
1 SPECIAL INTERROGATORY NO. 25: 2 4 5 DATED: February 7, 2012 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

298409 1.doc
For each of the PERSONS identified in response to Special Interrogatory No.
3 24, state the date(s) each PERSON was a member of Yea! Network, LLC. KELLEY DRYE 8.E. WARREN LLP Michael J. O'Connor Andrew W. DeFrancis By Andrew W. rancis Attorneys for Plainti NZK Productions Inc. and Horizon Alternative Television Inc.
Exhibit C Page 18
PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles, State of California. My 4 business address is 10100 Santa Monica Boulevard, Twenty-Third Floor, Los Angeles, California 90067. 5 On February 7, 2012, I served a true copy of the foregoing document described as PLAINTIFF NZK PRODUCTIONS INC.'S-FIRST SET OF 6 SPECIAL INTERROGATORIES TO DEFENDANT REALITY STEVE, LLC on the interested parties in this action as follows: 7 3 8 9 10 11 12
E3 BY FEDERAL EXPRESS: I enclosed said document in an envelope or package provided by Federal Express and addressed to the persons at the addresses 14 listed in the Service List. I_placed the envelope or package for collection and 15 overnight delivery at an office or a regularly utilized drop box of Federal Express or delivered such document to a courier or driver authorized by Federal Express to receive documents. 16
D. Bradley Kizzia, Esq. Brown Fox Kizzia & Yohnson PLLC 8226 Douglas Avenue, Suite 411 Dallas, TX 75225 Fax: 214-613-3330 brad@brownfoxlaw.corn Attorneys for defendants Stephen Carbone and Reality Steve, LLC
Gregg A. Farley, Esq. Law Offices of Gregg A. Farley 11755 Wilshire Boulevard, Suite 1845 Los Angeles, CA 90025 Fax: 310-445-4109 gfarley@farleyfirm.corn Attorneys for defendants Stephen Carbone and Reality Steve, LLC
13
FEDERAL: I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am 18 employed in the office of a member of the bar of this Court at whose direction the service was made. 19 Executed on February 7, 2012, at Los Angeles, California. 20 17 21 22 23 24 25 26 27 28
298409 I doc
Karen M. jaden --..'
Exhibit C Page 19
EXHIBIT D TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT D TO DECLARATION OF ANDREW W. DeFRANCIS
1 KELLEY DRYE & WARREN LLP Michael J. O'Connor (STATE BAR NO. 90017) 2 Andrew W. DeFrancis (STATE BAR NO. 246399) 10100 Santa Monica Boulevard, Twenty-Third Floor 3 Los Angeles California 90067-4008 Telephone: 310) 712-6100 4 Facsimile: 10) 712-6199 moconnor kelleydrye.com 5 adefrancis kelleydrye.com 6 Attorneys for Plaintiffs NZK PRODUCTIONS INC. and 7 HORIZON ALTERNATIVE TELEVISION INC. 8 9 10 11 NZK PRODUCTIONS INC., a 13 California corporation, and HORIZON ALTERNATIVE TELEVISION INC., a 14 Delaware corporation, 15 16 V. Plaintiffs, 12 CASE NO. CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT STEPHEN CARBONE Date: Time: Place: April 4, 2012 9:00 a.m. Quilling, Selander, Lownds, Winslett & Moser, P.C. 2001 Bryan Street, Ste. 1800 Dallas, TX 75201 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
17 STEPHEN CARBONE, an individual, REALITY STEVE, LLC, a Texas 18 limited liability corporation, and DOES 1 through 10, Inclusive, 19 Defendants. 20 21 22 23 24 25 26 27
Exhibit D
28
298976.1.doc
Page 20
CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT STEPHEN CARD ONE
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules of 3 Civil Procedure, Plaintiffs NZK Productions Inc. and Horizon Alternative 4 Television Inc. (collectively, "Plaintiffs") will conduct the deposition of Defendant 5 Stephen Carbone on April 4, 2012, at 9:00 a.m. at the offices of Quilling, Selander, 6 Lownds, Winslett & Moser, P.C., 2001 Bryan Street, Suite 1800, Dallas, Texas 7 75201. 8 The deposition will be conducted upon oral examination and will be recorded 9 stenographically and/or by videotape before a certified shorthand reporter, notary 10 public or other person authorized by law to take depositions and administer oaths 11 and will continue from day to day, excluding Sundays and holidays, until 12 completed. 13 PLEASE TAKE FURTHER NOTICE that Plaintiffs reserve the right to 14 record the testimony of this deponent by stenographic method through the use of 15 realtime and will provide rough draft transcripts, if requested. 16 17 DATED: March 6, 2012 18 19 20 21 22 23 24 25 26 27 28
298976.1 .doc
KELLEY DRYE & WARREN Michael J. O'Connor Andrew W. DeFrancis By
LLP
Andrew W Francis Attorneys for Plaintiffs NZK Productions Inc. and Horizon Alternative Television Inc.
Exhibit D Page 21
CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT STEPHEN CARBONE
1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 4 business address is 10100 Santa Monica Boulevard, Twenty-Third Floor, Los Angeles, California 90067. 5 On March 6, 2012, I served a true copy of the foregoing document described 6 as NOTICE OF DEPOSITION OF DEFENDANT STEPHEN CARBONE on the interested parties in this action as follows: 7 Gregg A. Farley, Esq. D. Bradley Kizzia, Esq. Brown Fox Kizzia & Johnson PLLC Law Offices of Gregg A. Farley 8 8226 Douglas Avenue, Suite 411 11755 Wilshire Boulevard, Suite 1845 Dallas, TX 75225 Los Angeles CA 90025 9 Fax: 310-445-4109 Fax: 214-613-3330 gfarley@farleyfirm.corn 10 brad@brownfoxlaw.com Attorneys for defendants Stephen Attorneys for defendants Stephen Carbone and Reality Steve, LLC Carbone and Reality Steve, LLC 11 12 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeless State of California. My
BY FEDERAL EXPRESS: I enclosed said document in an envelope or package provided by Federal Express and addressed to the persons at the addresses 14 listed in the Service List. I_placed the envelope or package for collection and overnight delivery at an office or a. regularly utilized drop box of Federal Express or 15 delivered such document to a courier or driver authorized by Federal Express to receive documents. 16 E21 FEDERAL: I declare under penalty of perjury under the laws of the 17 United States of America that the foregoing is true and correct and that I am employed in the office of a member of the bar of this Court at whose direction the 18 service was made.
13
E3
19 20 21 22 23 24 25 26 27 28
Executed on March 6, 2012, at Los Angeles, California.
Karen M. 'Ijaden
Exhibit D Pace 22
298976.1.doc
CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT STEPHEN CARBONE
1 KELLEY DRYE & WARREN LLP Michael J. O'Connor (STATE BAR NO. 90017) 2 Andrew W. DeFrancis (STATE BAR NO. 246399) 10100 Santa Monica Boulevard, Twenty-Third Floor 3 Los Angeles California 90067-4008 Telephone: 310) 712-6100 4 Facsimile: 10) 712-6199 mocoimor@kelleydrye.com 5 adefrancis kelleydrye.corn 6 Attorneys for Plaintiffs NZK PRODUCTIONS INC. and 7 HORIZON ALTERNATIVE TELEVISION INC. 8 9 10 11 NZK PRODUCTIONS NC a 13 California corporation, and HORIZON ALTERNATIVE TELEVISION NC., a 14 Delaware corporation, 15 16 V. Plaintiffs, 12 CASE NO. CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLC PURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE Date: Time: Place: April 4, 2012 2:00 p.m. Selander, Lownds, Winslett & Moser, P.C. 2001 Bryan Street, Ste. 1800 Dallas, TX 75201 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
17 STEPHEN CARBONE, an individual, REALITY STEVE, LLC, a Texas 18 limited liability corporation, and DOES 1 through 10, inclusive, 19 Defendants. 20 21 22 23 24 25 26 27 28
298975.1.doc
Exhibit D
Pic 21 CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLC PURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules
3 of Civil Procedure, Plaintiffs NZK Productions Inc. and Horizon Alternative 4 Television Inc. (collectively, "Plaintiffs") will conduct the deposition of Defendant 5 Reality Steve, LLC on April 4, 2012, at 2:00 p.m. at the offices of Quilling, 6 Selander, Lownds, Winslett & Moser, P.C., 2001 Bryan Street, Suite 1800, Dallas, 7 Texas 75201. Reality Steve, LLC shall designate one or more of its officers, 8 directors, employees or other persons who shall testify as to all matters known or 9 reasonably available to it with regard to the topics in Attachment A hereto. 10 The deposition will be conducted upon oral examination and will be recorded
11 stenographically and/or by videotape before a certified shorthand reporter, notary 12 public or other person authorized by law to take depositions and administer oaths 13 and will continue from day to day, excluding Sundays and holidays, until 14 completed. 15 PLEASE TAKE FURTHER NOTICE that Plaintiffs reserve the right to 16 record the testimony of this deponent by stenographic method through the use of 17 realtime and will provide rough draft transcripts, if requested. 18 19 DATED: March 6, 2012 20 21 22 23 24 25 26 27 28
298975.1.doc
KELLEY DRYE & WARREN Michael J. O'Connor Andrew W. DeFrancis
LLP
By 6;2 Andrew W Francis Attorneys for Plain fs NZK Productions Inc. and Horizon Alternative Television Inc.
Exhibit D Page 24
CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLC PURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE
1 2 3
ATTACHMENT A DEFINITIONS "REALITY STEVE, LLC," as used herein, shall mean Defendant Reality
4 Steve, LLC, including the agents, attorneys, employees, officers, representatives, 5 directors, consultants, or others acting on (or who acted on) its behalf. 6 7 TOPIC NO. 1: 8 REALITY STEVE, LLC's contracts with third-parties, particularly those 9 located in California. 10 TOPIC NO. 2: 11 REALITY STEVE, LLC's involvement in the creation and operation of the 12 website located at www.realitysteve.com . 13 TOPIC NO. 3: 14 Reality Steve, LLC's revenue and income, as well as the sources whereby that 15 revenue and income is derived. 16 TOPIC NO. 4: 17 Reality Steve, LLC's tax returns, from January 1, 2004, through the present. TOPICS
18 TOPIC NO. 5: 19 Reality Steve, LLC's involvement in any lawsuits, from January 1, 2004, 20 through the present 21 TOPIC NO. 6: 22 The office locations of Reality Steve, LLC.
23 TOPIC NO. 7: 24 Property owned by or on behalf of Reality Steve, LLC. Exhibit D

Page 25
25 TOPIC NO. 8: 26 The officers and members of Reality Steve, LLC.
27 TOPIC NO. 9: 28 The formation and corporate structure of Reality Steve, LLC.
298975.1.doc
ATTACHMENT A
CV11-10118 GHK (Ex)
1 TOPIC NO. 10: 2 Travel undertaken on behalf of Reality Steve, LLC, including travel to 3 promote the website located at www.realitysteve.com . 4 TOPIC NO. 11: 5 Contacts between REALITY STEVE, LLC and residents of or companies
6 located in California. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
298975.1.doc
Exhibit D Page 26
ATTACHMENT A
CV11-10118GHK (Ex)
1
3
PROOF OF SERVICE
At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles State of Cahfornia. My
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 business address is 10100 Santa Monica Boulevard, Twenty-Third Floor, Los Angeles, California 90067. 5 On March 6, 2012, I served a true copy of the foregoing, document described as NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLC 6
PURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL 7 PROCEDURE on the interested parties in this action as follows:
8 9 10 11 12 D. Bradley Kizzia, Esq. Brown Fox Kizzia & Johnson PLLC 8226 Douglas Avenue, Suite 411 Dallas, TX 75225 Fax: 214-613-3330 brad@brownfoxlaw.corn Attorneys for defendants Stephen Carbone and Reality Steve, LLC
Gregg A. Farley, Esq. Law Offices of Gregg A. Farley 11755 Wilshire Boulevard, Suite 1845 Los Angeles, CA 90025 Fax: 310-445-4109 gfarley@farleyfirm.corn Attorneys for defendants Stephen Carbone and Reality Steve, LLC
E3 BY FEDERAL EXPRESS: I enclosed said document in an envelope or package provided by Federal Express and addressed to the persons at the addresses 14 listed in the Service List. I_placed the envelope or package for collection and 15 overnight delivery at an office or a regularly utilized drop box of Federal Express or delivered such document to a courier or driver authorized by Federal Express to 16 receive documents.
13
FEDERAL: I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am 18 employed in the office of a member of the -bar of this Court at whose direction the service was made. 19 Executed on March 6, 2012, at Los Angeles, California. 20 17 21 22 23 24 25 26 27 28
298975.1.doc
Karen M. aden
L4
LJ
Exhibit D Page 27
CV11-10118 GHK (Ex) NOTICE OF DEPOSITION OF DEFENDANT REALITY STEVE, LLC PURSUANT TO RULE 30(B)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE
EXHIBIT E TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT E TO DECLARATION OF ANDREW W. DeFRANCIS
1
2 3
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Gregg A. Farley, SBN 115593 LAW OFFICES OF GREGG A. FARLEY 11755 Wilshire Blvd., Ste. 1845 Los Angeles, CA 90025 Telephone: (310) 445-4024 Facsimile: (310) 445-4109 gfarley@farleyfirm.com D. Bradley Kizzia (Pro Hac Vice) BROWN FOX KIZZIA & JOHNSON PLLC 8226 Douglas Avenue, Suite 411 Dallas, Texas 75225 Telephone: (469) 893-9940 Facsimile: (214) 613-3330 brad@brownfoxlaw.com Attorneys for Defendants STEPHEN CARBONE and REALITY STEVE, LLC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
NZK PRODUCTIONS INC., a ) California corporation, and HORIZON ) ALTERNATIVE TELEVISION INC., a) Case No.: CV11-10118-GHK (Ex) Delaware corporation, Plaintiffs, DEFENDANT STEPHEN CARBONE'S RESPONSES TO STEPHEN CARBONE, an individual, PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL and REALITY STEVE, LLC, a Texas INTERROGATORIES limited liability corporation,
V S.
Defendants.
.-1-
sr
Exhibit E Page 28
STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC. RESPONDING PARTY: SET NO.: DEFENDANT STEPHEN CARBONE ONE
26 27 28 -2-
Exhibit E Page 29
1 2 3
TO: THE PARTIES AND TO THEIR ATTORNEYS OF RECORD:
SPECIAL INTERROGATORY NO. 1:

IDENTIFY all PERSONS who contacted YOU at steve@realitysteve.com concerning THE BACHELOR SERIES between January 1, 2004, and the present. The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as to an individual, stating his or her full and customarily used names, present resident address, business address, and business telephone number; (b) as to any person
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
other than an individual, stating its legal name and any other names used by it, the form or manner of its organization (e.g., partnership, corporation, etc.), the state of its incorporation (if it is incorporated) or the state of its formation (if it is a partnership or limited liability company), and the address of its principal place of business; (c) as to any document, its author, recipient, sender, date(s), its subject matter, the number of pages therein, and wherever possible its corresponding BATES number(s); and (d) as to an event, transaction, or occurrence stating its date, the location and the manner of its occurrence (e.g., face-to-face meeting of participants, telephone calls, etc.), the identification of all its participants and eyewitnesses to its occurrence, its purpose and subject matter, a concise description of what transpired, and IDENTIFY any document referring to or concerning said event, transaction, or occurrence.
Exhibit E
-3-
28
Page 30
STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, INC..'S FIRST SET OF SPECIAL INTERROGATORIES
1 2 3
The terms "PERSON" and "PERSONS," as used in these Interrogatories, shall mean all natural persons, partnerships, consortia, joint ventures, and every other form of legally recognized entity, including corporations.
4 5 6 7 8
The terms "YOU," "YOUR," or " DEFENDANT," as used in these Interrogatories, shall mean Defendant Stephen Carbone, acting in his individual capacity or as an agent of Defendant Reality Steve, LLC. The term "THE BACHELOR SERIES," as used in these Interrogatories,
10 11 12 13 14 15 16 17 18 19 20
shall mean "The Bachelor," "The 13achelorette" and/or the "Bachelor Pad" television series.
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is
21 22 23 24 25 26 27 28
proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about nonpublic information concerning the Bachelor series since January 1, 2011. However,
-4STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
Exhibit E Page 31
1 2 3 4 5 6 7 8 9 10 11 12 13
on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received. SPECIAL INTERROGATORY NO. 2: State the date(s) that each PERSON identified in response to Special Interrogatory No. 1 contacted YOU. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is
14 15 16 17 18 19 20
relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, on or about October 24, 2011, November 16, 2011 and
21 22 23 24 25 26 27 28 -5-
November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.
Exhibit E Page 32

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
IDENTIFY
all
PERSONS
who
YOU contacted
from
steve@realitysteve.corn concerning THE BACHELOR SERIES between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about nonpublic information concerning the Bachelor series since January 1, 2011.
21 22 23 24 25 26 27 28 -6-
However, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.
Exhibit E Page 33

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
State the date(s) that you contacted each PERSON identified in response to Special Interrogatory NO. 3. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received. SPECIAL INTERROGATORY NO. 5:
21 22 23 24 25 26 27 28
IDENTIFY all PERSONS who contacted YOU at twitter.com/realitysteve concerning THE BACHELOR SERIES between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is
Exhibit E Page 34
1
2 3 4
relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and
6 7 8 9 10 11 12 13
without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about nonpublic information concerning the Bachelor series since January 1, 2011. However, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons
14 15 16 17 18 19 20
who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.

State the date(s) that each PERSON identified in response to Special Interrogatory No. 5 contacted YOU.
21 22 23 24 25 26 27 28
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not
Exhibit E Page 35
1 2
reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.
4 5 6 7 8 9 10.

IDENTIFY all PERSONS who YOU contacted from
12 13
twitter.com/realitysteve concerning THE BACHELOR SERIES between January 1, 2004, and the present.
14 15 16 17 18 19 20
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not
22 . 23 24 25 26 27 28
reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about non-9STEPHEN CARI3ONE'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
Exhibit E Page 36
1 2 3 4 5 6 7 8 9 10 11 12 13
public information concerning the Bachelor series since January 1, 2011. However, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.

State the date(s) that YOU contacted each PERSON identified in response to Special Interrogatory No. 7.
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad,
14 15 16 17 18 19 20
unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and
21 22 23 24 25 26 27 28 -10STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
without waiving same, on or about October 24, 2011, November 16, 2011 and November 18, 2011, Defendant sent three electronic communications to the following persons who do NOT live in California: Jaclyn Swartz, Emily O'Brien and Casey Shteamer. However, no responsive information was received.
Exhibit E Page 37

2 3 4 5 6 7 8 9
IDENTIFY each public appearance that YOU made to promote www.realitysteve.com between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad and not reasonably limited to information that is relevant to Defendant's objection to jurisdiction in California. Subject to the foregoing objections and without waiving same, Defendant responds as follows: Appearance on WFAA Channel 8 in Dallas, Texas on March 14, 2011. Appearance at Bailey's Prime Plus in Dallas, Texas on March 14, 2011. Three (3) additional appearances on WFAA Channel 8 in Dallas, Texas. SPECIAL INTERROGATORY NO. 10: IDENTIFY each INTERVIEW YOU gave concerning THE BACHELOR SERIES between January 1, 2004, and the present. The term "INTERVIEW," as used in these Interrogatories, shall mean any
10 11
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
type of media appearance, including but not limited to television, radio, print, or other type of media appearance. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad and not reasonably limited to information that is relevant to Defendant's objection to
Exhibit E Page 38
jurisdiction in California. Subject to the foregoing objections and without waiving same, see Answer to Special Interrogatory No. 9. Additionally, there were various radio interviews, but none in California. SPECIAL INTERROGATORY NO. 11: IDENTIFY each ARTICLE that YOU authored concerning THE BACHELOR SERIES between January 1, 2004, and the present. The term "ARTICLE," as used in these Interrogatories, shall mean any writing that appears on the intemet, in an email or print newsletter, in a newspaper, in a magazine, or in any other print publication. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad and not reasonably limited to information that is relevant to Defendant's objection to jurisdiction in California. Subject to the foregoing objections and without waiving same, see www.realitysteve.com . SPECIAL INTERROGATORY NO. 12: IDENTIFY each PERSON from whom YOU received any information concerning THE BACHELOR SERIES between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is
Exhibit E Page 39
relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and
2 3 4
6 7 8
without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about non-
10 11 12 13
public information concerning the Bachelor series since January 1, 2011. SPECIAL INTERROGATORY NO. 13: For each of the PERSONS identified in response to Special Interrogatory
14 15 16 17 18 19 20
No. 12, state the date(s) each PERSON provided YOU with information about THE BACHELOR SERIES. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is
21 22 23 24 25 26 27 28
relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, see Answer to Special Interrogatory No. 12.
Exhibit E Page 40

2 3 4 5 6 7
IDENTIFY all communications that YOU initiated with any PERSON who is or was a resident of California concerning the BACHELOR SERIES. ANSWER: I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any
9 10 11 12 13 14 15 16 17 18 19 20
communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011. SPECIAL INTERROGATORY NO. 15: IDENTIFY all communications that YOU initiated with any PERSON who is or was a resident of California concerning www.realitysteve.com . ANSWER: I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about non-public information
21 22 23 24 25 26 27 28 -14STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
concerning the Bachelor series since January 1, 2011. SPECIAL INTERROGATORY NO. 16: IDENTIFY all communications that YOU received from any PERSON who is or was a resident of California concerning THE BACHELOR SERIES.
Exhibit E Page 41
1 2 3
ANSWER:
I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any
4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011.

IDENTIFY all communications that YOU received from any PERSON who is or was a resident of California concerning www.realitysteve.com .
ANSWER:
I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have made or received any communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011.

IDENTIFY all trips that you made to California between January 1, 2004,
21 22 23 24 25 26 27 28 -15-
and the present.
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad and unduly burdensome. Subject to these objections and without waiving same,
Exhibit E Page 42
Defendant visited California approximately five (5) six (6) times per year from
2 3 4 5 6 7
January 1, 2006 through the present.

For each of the trips identified in response to Special Interrogatory No. 18, IDENTIFY where you stayed while visiting California.
ANSWER:
9 10 11 12 13 14 15 16 17 18 19 20
Defendant objects to this Special Interrogatory because it is overbroad and unduly burdensome. Subject to these objections and without waiving same, in the Huntington Beach area with family or in hotels.

Describe the purpose of each of the trips identified in response to Special Interrogatory No. 18.
ANSWER:
Defendant objects to this Special Interrogatory because it is overbroad and unduly burdensome. Subject to these objections and without waiving same, the
21 22 23 24 25 26 27 28
trips to California were personal and not for business. Instead, they were for birthdays, vacations, and/or to visit family.

IDENTIFY all real estate that YOU own in California, including any real estate that you jointly own with another PERSON.
Exhibit E
-16-
Page 43
1 2 3 4 5 6 7 8 9 10 11 12 13
ANSWER: Defendant does not own any real estate in California. SPECIAL INTERROGATORY NO. 22: IDENTIFY all bank accounts that YOU own or control in California. ANSWER: Defendant does not own or control any bank accounts in California. SPECIAL INTERROGATORY NO. 23: IDENTIFY all sources of income that YOU derive from California, including all income derived from PERSONS who reside in California. ANSWER:
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Defendant does not derive any income from California. SPECIAL INTERROGATORY NO. 24: IDENTIFY each time that YOU paid income taxes in California between January 1, 2004, and the present. ANSWER:
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Defendant has not paid income taxes in California between January 1, 2004 and the present. SPECIAL INTERROGATORY NO. 25: IDENTIFY each time that YOU voted in an ELECTION as a California resident between January 1, 2004, and the present.
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Exhibit E Page 44
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
The term "ELECTION," as used in these Interrogatories, shall mean any type of political election, including local, statewide, and national elections. ANSWER: Defendant has not voted in an election as a California resident between January 1, 2004 and the present.
DATED: March 0,--2012 BROWN FOX KIZZIA & JOHNSON PLLC
By: D. Bradley Kizzia (P Attorneys for De endan and Reality Steve, LLC DATED: March , 2012 LAW OFFICES OF GREGG A. FARLEY e) ephen Carbone
By:
r A. Farley Attorneys for Defendants Stephen Carbone and Reality Steve, LLC
-18STEPHEN CARBONE'S RESPONSES TO NZK PRODUCTIONS, fNC.'S FIRST SET OF SPECIAL INTERROGATORIES
Exhibit E Page 45
1 2 3 4 5 6 7
Gregg A. Farley, SBN 115593 (local counsel) LAW OFFICES OF GREGG A. PARLEY 11755 Wilshire Blvd., Ste. 1845 Los Angeles, CA 90025 Telephone: (310) 445-4024 Facsimile: (310) 445-4109 gfarley@farleyfirrn.eom D. Bradley Kizzia (Pro Hac Vice) BROWN FOX KIZZIA & JOHNSON PLLC 8226 Douglas Avenue, Suite 411 Dallas, Texas 75225 Telephone: (469) 893-9940 Facsimile: (214) 613-3330 brad@brownfoxlaw.com Attorneys for Defendants STEPHEN CARBONE and REALITY STEVE, LLC
9 10 11 12 13 14 15 16 17 18 19 20
NZK PRODUCTIONS INC., a ) California corporation, and HORIZON ) ALTERNATIVE TELEVISION INC., a) Case No.: CV11-10118-GHK (Ex) Delaware corporation,
)
Plaintiffs,
VS.
21 22 23 24 25 26 27 28
STEPHEN CARBONE, an individual, and REALITY STEVE, LLC, a Texas limited liability corporation, Defendants.
DECLARATION OF STEPHEN CARBONE IN SUPPORT OF REALITY STEVE, LLC'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
DECLARATION OF STEPHEN CARBONE -1-
Exhibit E Page 46
DECLARATION OF STEPHEN CARBONE

I, Stephen Carbone, declare and state: 1. My name is Stephen Carbone. I am a Defendant in this lawsuit. I am capable of
making this Declaration. I have read the attached answers to Plaintiff NZK Production Inc.'s
6 7 8
First Set of Special Interrogatories, and every statement contained therein is within my personal
knowledge and is true and correct. I declare under penalty of perjury of the laws of the United States of America that the
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
above facts are true and correct, and that this Declaration was executed this -74 day of March, 2012 in Dallas, Texas.
Stepl en Crbne
Exhibit E Page 47
PROOF OF SERVICE
2
STATE OF TEXAS, COUNTY OF DALLAS

3 4 5 6 7 8 9
At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Dallas, State of Texas. My business address is 8226 Douglas Avenue, Suite 411, Dallas, Texas 75225 On March 9, 2012 I served a true copy of the foregoing document described as
DEFENDANT STEPHEN CARBONE'S RESPONSES TO PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL INTERROGATORIES
on the interest parties in this action as follows: Michael J. O'Conner, Esq Andrew W. DeFrancis, Esq KELLEY DRYE & WARREN LLP 10100 Santa Monica Boulevard, Twenty-Third Floor Los Angeles, CA 90067-4008 Tel: (310)712-6100 Fax: (310) 712-6199 moconner@kelleydrye.com adefrancis@kelleydrye.com
Attorneys for Plaintiff NZK Productions, Inc. a California Corporation and Horizon Alternative Television, Inc., a Delaware Corporation
10
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
BY UNITED STATE POSTAL SERVICE: I enclosed a said document in an envelope or package and addressed to the persons at the addresses listed in the Service List. I placed the envelope or package for collection at an office or regularly utilized drop box of United States Postal Service or delivered such document to a courier or driver authorized by the United States Postal Service. FEDERAL: I declared under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am a member of the State Bar of Texas and have been admitted to practice before this court Pro Hac Vice. Executed on March 9, 2012, at Dallas, Texas.
26 27 28
. D. Bddleif la
Exhibit E Page 48
EXHIBIT F TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT F TO DECLARATION OF ANDREW W. DeFRANCIS
2 3 4
Gregg A. Farley, SBN 115593 LAW OFFICES OF GREGG A. FARLEY 11755 Wilshire Blvd., Ste. 1845 Los Angeles, CA 90025 Telephone: (310) 445-4024 Facsimile: (310) 445-4109 gfarley@farleyfirm.corn D. Bradley Kizzia (Pro Hac Vice) BROWN FOX KIZZIA & JOHNSON PLLC 8226 Douglas Avenue, Suite 411 Dallas, Texas 75225 Telephone: (469) 893-9940 Facsimile: (214) 613-3330 brad@brownfoxlaw.corn Attorneys for Defendants STEPHEN CARBONE and REALITY STEVE, LLC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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NZK PRODUCTIONS INC., a ) California corporation, and HORIZON ) ALTERNATIVE TELEVISION INC., a) Case No.: CV11-10118-GHK (Ex) ) Delaware corporation, ) ) Plaintiffs, ) DEFENDANT REALITY STEVE, VS. LLC'S RESPONSES TO PLAINTIFF NZK PRODUCTIONS INC.'S FIRST STEPHEN CARBONE, an individual, SET OF SPECIAL and REALITY STEVE, LLC, a Texas INTERROGATORIES limited liability corporation, Defendants.
Exhibit F -1Page 49
REALITY STEVE, LLC'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
PROPOUNDING PARTY: PLAINTIFF NZK PRODUCTIONS INC. RESPONDING PARTY: SET NO.: DEFENDANT REALITY STEVE, LLC ONE
Exhibit F
-2-
Page 50
TO: THE PARTIES AND TO THEIR ATTORNEYS OF RECORD:

2 3 4 5 6 7

IDENTIFY each PERSON with whom YOU registered www.realitysteve.com between January 1, 2004, and the present. The term "IDENTIFY," as used in these Interrogatories, shall mean: (a) as to an individual, stating his or her full and customarily used names, present resident
10
address, business address, and business telephone number; (b) as to any person
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
other than an individual, stating its legal name and any other names used by it, the form or manner of its organization (e.g., partnership, corporation, etc.), the state of its incorporation (if it is incorporated) or the state of its formation (if it is a partnership or limited liability company), and the address of its principal place of business; (c) as to any document, its author, recipient, sender, date(s), its subject matter, the number of pages therein, and wherever possible its corresponding BATES number(s); and (d) as to an event, transaction, or occurrence stating its date, the location and the manner of its occurrence (e.g., face-to-face meeting of participants, telephone calls, etc.), the identification of all its participants and eyewitnesses to its occurrence, its purpose and subject matter, a concise description of what transpired, and IDENTIFY any document referring to or concerning said event, transaction, or occurrence.
Exhibit F
-3-
28
Page 51
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
The terms "PERSON" and "PERSONS," as used in these Interrogatories, shall mean all natural persons, partnerships, consortia, joint ventures, and every other form of legally recognized entity, including corporations. The terms "YOU," "YOUR," or " DEFENDANT," as used in these Interrogatories, shall mean Defendant Reality Steve, LLC and each of its past and present agents, associates, managers, representatives, accountants, attorneys, and anyone else acting, or who has acted, on its behalf, including Defendant Stephen Carbone. ANSWER: www.realitysteve.com has only been registered with Stephen Carbone since January 1, 2004. SPECIAL INTERROGATORY NO. 2: State the date(s) YOU registered www.realitysteve.com with each of the PERSONS identified in response to Special Interrogatory No. 1. ANSWER:
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The website was registered with Stephen Carbone on or around January 1, 2004. SPECIAL INTERROGATORY NO. 3: IDENTIFY each PERSON who HOSTED www.realitysteve.com between January 1, 2004, and the present.
-4-
Exhibit F Page 52
The term "HOSTED," as used in these Interrogatories, shall mean the act of providing server space, internet services, and/or file maintenance for websites.
ANSWER:
Yahoo Small Business and StormDemand.com have hosted www.realitysteve.com between January 1, 2004 and the present.

State the date(s) that each PERSON identified in response to Special Interrogatory NO. 3 HOSTED www.realitysteve.com .
ANSWER:
Yahoo Small Business hosted the website until January 26, 2010. www.StormonDemand.com has hosted the website from January 26, 2010 through the present.

IDENTIFY all agreements of any kind entered into between January 1, 2004, and the present concerning advertising on www.realitysteve.com .
ANSWER:
Defendant objects to this Special Interrogatory on the grounds that it is overly broad, vague and unduly burdensome. Subject to the foregoing objections and without waiving same, Reality Steve has entered into agreements with the following companies concerning advertising on the website: Google Adsense,
-5REALITY STEVE, LLC'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
Exhibit F Page 53
Value Click, Lijit, CPMonly, Underground Media, Adtegrity, Vibrant, and

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Gunggo.

IDENTIFY all PERSONS who have purchased advertising on www.realitysteve.com between January 1, 2004, and the present.
ANSWER:
There have been a small number of independent advertisers that have purchased advertising on the website. The advertising purchased was only for a two-week period, and none of the advertisers were in California.
SPECIAL INTERROGATORY NO 7:
State all usemame accounts registered on www.realitysteve.com .
ANSWER:
Defendant objects to this Special Interrogatory on the grounds that it is unduly burdensome and not calculated to lead to the discovery of admissible evidence. Subject to the foregoing and without waiving same, Defendant responds
21 22 23 24 25 26 27 28
as follows: there are approximately 17,000 users on www.realityseve.com , and each user has logged onto the website and crated a username at some point in time.

For each of the usemame accounts identified in response to Special Interrogatory No. 7, state the email address affiliated with each account.
Exhibit F Page 54
1 2 3
ANSWER: Defendant objects to this Special Interrogatory on the grounds that it is unduly burdensome and not calculated to lead to the discovery of admissible
4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -7-
evidence. Subject to the foregoing and without waiving same, Defendant responds as follows: there are approximately 17,000 users on www.realityseve.com , and each user has logged onto the website and crated a username at some point in time. The email addresses do not reflect the user's state of residence. SPECIAL INTERROGATORY NO. 9: IDENTIFY all PERSONS who have a contractual relationship of any kind with www.realitysteve.com . ANSWER: Yea! Networks, LLC 220 E. Las Colinas Boulevard Suite C120 Irving, Texas 75039 Steve Cook Kris Drouet 25502 Coral Wood Street Lake Forest, California 92630 SPECIAL INTERROGATORY NO. 10: Describe YOUR contractual relationship with each PERSON identified in response to Special Interrogatory No. 9.
Exhibit F Page 55
REALITY STEVE, LLC'S RESPONSES TO NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORJES
1
2 3 4 5 6 7
ANSWER: Yea! Networks, LLC is a five percent (5%) owner of Reality Steve, LLC. Steve Cook is the manager of the Cooking Group, and was receiving a commission from www.realitysteve.com . Reality Steve's contractual relationship with Steve Cook ceased on February 15, 2012. Kris Drouet is an independent contractor who serves as Reality Steve's webmaster, and as such, receives a commission from www.realitysteve.com that is deposited in a bank account in Texas. The contract and the work that Mr. Drouet performs is done online and has nothing to do with his residence. He could live and be anywhere in the world and do his work as an independent contractor, as long as he has internet access.
8
9 10 11 12 13 14 15 16 17 18 19 20
SPECIAL INTERROGATORY NO. 11: IDENTIFY all members of Reality Steve, LLC from January 1, 2004, through the present. ANSWER: The members of Reality Steve, LLC have been, and currently are, Stephen
21 22 23 24 25 26 27 28 -8-
Carbone and Yea! Networks, LLC. SPECIAL INTERROGATORY NO. 12: For each of the PERSONS identified in response to Special Interrogatory No. 11, state the date(s) each PERSON was a member of Reality Steve, LLC.
Exhibit F Page 56
1
2
ANSWER: Stephen Carbone became a member of Reality Steve, LLC on July 11, 2011. Yea! Networks, LLC became a member of Reality Steve, LLC on August 17, 2011. SPECIAL INTERROGATORY NO. 13: State the monthly number of visitors to www.realitysteve.com between January 1, 2004, and the present. ANSWER: www.realitysteve.com has approximately 2,000,000 visitors per month. SPECIAL INTERROGATORY NO. 14:
4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
State the monthly number of visits to www.realitysteve.com by PERSONS located in California between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory on the grounds that it is unduly burdensome and not calculated to lead to the discovery of admissible
21 22 23 24 25 26 27 28 -9-
evidence. Subject to the foregoing and without waiving same, I do not know. The website has approximately 2,000,000 visitors per month, and the email addresses of the visitors do not indicate where the visitors live.
Exhibit F Page 57
1 2 3 4 5 6 7 8 9 10 11 12 13
SPECIAL INTERROGATORY NO. 15: State the monthly number of visits to www.realitysteve.com by computers located in California between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory on the grounds that it is unduly burdensome and not calculated to lead to the discovery of admissible evidence. Subject to the foregoing and without waiving same, I do not know. The email address of each person who visits the website does not indicate the location of each person's computer. SPECIAL INTERROGATORY NO. 16:
14 15 16 17 18 19 20
IDENTIFY all bank accounts that YOU own or control in California. ANSWER: Reality Steve, LLC does not own or control any bank accounts in California. SPECIAL INTERROGATORY NO. 17: IDENTIFY all sources of income that YOU derive from California,
21 22 23 24 25 26 27 28 -10-
including all income derived from PERSONS who reside in California. ANSWER: Reality Steve, LLC does not derive any income from California..
Exhibit F Page 58
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
SPECIAL INTERROGATORY NO. 18: IDENTIFY each time that YOU paid income taxes in California between January 1, 2004, and the present. ANSWER: Reality Steve, LLC has not paid any income taxes in California between January 1, 2004 and the present. SPECIAL INTERROGATORY NO. 19: IDENTIFY all trips to California made on behalf of YOU between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad and unduly burdensome. Subject to these objections and without waiving same, no trips have been made to California on behalf of Reality Steve, LLC between January 1, 2004 and the present. SPECIAL INTERROGATORY NO. 20: Describe the purpose of each of the trips identified in response to Special Interrogatory No. 19.
Exhibit F Page 59
ANSWER:
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Defendant objects to this Special Interrogatory because it is overbroad and unduly burdensome. Subject to these objections and without waiving same, see Answer to Special Interrogatory No. 19. SPECIAL INTERROGATORY NO. 21: IDENTIFY each PERSON from whom YOU received any information concerning THE BACHELOR SERIES between January 1, 2004, and the present. The term "THE BACHELOR SERIES," as used in these Interrogatories, shall mean "The Bachelor," "The Bachelorette" and/or the "Bachelor Pad" television series. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not
21 22 23 24 25 26 27 28 -12-
reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to these objections and without waiving same, I do not recall any names, dates or details of possible communications with California residents years go, but I do not believe I have
Exhibit F Page 60
made or received any communications with residents of California about non2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
public information concerning the Bachelor series since January 1, 2011. SPECIAL INTERROGATORY NO. 22: For each of the PERSONS identified in response to Special Interrogatory No. 21, state the date(s) that each PERSON provided YOU with information about THE BACHELOR SERIES. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad, unduly burdensome, and not reasonably limited in scope to information that is relevant to Defendant's objection to jurisdiction in California. Defendant further objects because as stated, the interrogatory seeks irrelevant information not reasonably calculated to lead to admissible evidence and information that is proprietary and subject to the journalistic privilege. Subject to .these objections and without waiving same, see Answer to Special Interrogatory No. 21. SPECIAL INTERROGATORY NO. 23: IDENTIFY each public appearance that YOU made to promote www.realitysteve.com between January 1, 2004, and the present. ANSWER: Defendant objects to this Special Interrogatory because it is overbroad and not reasonably limited to information that is relevant to Defendant's objection to
Exhibit F Page 61
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
jurisdiction in California. Subject to the foregoing objections and without waiving same, Defendant responds as follows: Appearances on WFAA Channel 8 in Dallas, Texas March 14, 2011. Appearance at Bailey's Prime Plus in Dallas, Texas March 14, 2011. Three additional appearances on WFAA Channel 8 in Dallas, Texas. Various radio interviews, but not in California.

IDENTIFY each member of YOUR member Yea! Network, LLC, as identified at page 7 of YOUR MOTION TO DISMISS. The term "MOTION TO DISMISS," as used in these Interrogatories, shall mean Defendants Stephen Carbone and Reality Steve, LLC's Motion to Dismiss for Lack of Personal Jurisdiction in this matter, filed on January 20, 2012.
ANSWER:
See Defendants' Response to the Court's February 9, 2012 Order to Show Cause Re: Citizenship of Reality Steve, LLC and the Declarations and exhibits
21 22 23 24 25 26 27 28 -14-
filed therewith.

For each of the PERSONS identified in response to Special Interrogatory No. 24, state the date(s) each PERSON was a member of Yea! Network, LLC.
Exhibit F Page 62
1 2 3
ANSWER:
See Defendants' Response to the Court's February 9, 2012 Order to Show Cause Re: Citizenship of Reality Steve, LLC and the Declarations and Exhibits
4 5 6 7
filed therewith. See also Defendant's Answer to Special Interrogatory No. 12.
DATED: March /2012 BROWN FOX KIZZIA & JOHNSON PLLC

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
By: D. Bradley Kizzia (P Attorneys for Defendant and Reality Steve, LLC DATED: March hen Carbone
2012 LAW OFFICES OF GREGG A. FARLEY
By:
"Zi-L7L Gvg Attorneys for Defendants Stephen Carbone and Reality Steve, LLC
25 26 27 28 -15-
REALITY STEVE, LLC'S RESPONSES TO

NZK PRODUCTIONS, INC.'S FIRST SET OF SPECIAL INTERROGATORIES
Exhibit F Page 63
1 2 3 4 5 6 7
Gregg A. Farley, SBN 115593 (local counsel) LAW OFFICES OF GREGG A. FARLEY 11755 Wilshire Blvd., Ste. 1845 Los Angeles, CA 90025 Telephone: (310) 445-4024 Facsimile: (310) 445-4109 gfarley@farleyfirm.corn D. Bradley Kizzia (Pro Hac Vice) BROWN FOX KIZZIA & JOHNSON PLLC 8226 Douglas Avenue, Suite 411 Dallas, Texas 75225 Telephone: (469) 893-9940 Facsimile: (214) 613-3330 brad@brownfoxlaw.com Attorneys for Defendants STEPHEN CARBONE and REALITY STEVE, LLC
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
NZK PRODUCTIONS INC., a ) California corporation, and HORIZON ) ALTERNATIVE TELEVISION INC., a) Case No.: CV11-10118-GHK (Ex) ) Delaware corporation, ) Plaintiffs, ) ) DECLARATION OF STEPHEN VS. ) CARB ONE IN SUPPORT OF STEPHEN CARBONE, an individual, ) STEPHEN CARBONE'S RESPONSES and REALITY STEVE, LLC, a Texas ) TO NZK PRODUCTIONS, INC.'S limited liability corporation, ) FIRST SET OF SPECIAL ) INTERROGATORIES Defendants.
Exhibit F Page 64
1 2 3 4 5
DECLARATION OF STEPHEN CARBONE I, Stephen Carbone, declare and state:
1.
My name is Stephen Carbone. I am a member of Defendant Reality Steve, LLC in
this lawsuit. I am capable of making this Declaration. I have read the attached answers to Plaintiff NZK Production Inc.'s First Set of Special Interrogatories, and every statement
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
contained therein is within my personal knowledge and is true and correct. I declare
above under penalty of perjury of the laws of the United States of America that the
facts are true and correct, and that this Declaration was executed this
7-6--
day of March,
2012 in Dallas, Texas.
Exhibit F Page 65
PROOF OF SERVICE
STATE OF TEXAS, COUNTY OF DALLAS At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Dallas, State of Texas. My business address is 8226 Douglas Avenue, Suite 411, Dallas, Texas 75225 On March 9, 2012 I served a true copy of the foregoing document described as . DEFENDANT REALITY STEVE LLC'S RESPONSES TO PLAINTIFF NZK PRODUCTIONS INC.'S FIRST SET OF SPECIAL ITERROGATORIES on the interest parties in this action as follows: Michael J. O'Conner, Esq Andrew W. DeFrancis, Esq KELLEY DRYE & WARREN LLP 10100 Santa Monica Boulevard, Twenty-Third Floor Los Angeles, CA 90067-4008 Tel: (310)712-6100 Fax: (310) 712-6199 moconner@kelleydrye.com adefrancis@kelleydrye.com
Attorneys for Plaintiff NZK Productions, Inc. a California Corporation and Horizon Alternative Television, Inc., a Delaware Corporation
BY UNITED STATE POSTAL SERVICE: I enclosed a said document in an envelope or package and addressed to the persons at the addresses listed in the Service List. I placed the envelope or package for collection at an office or regularly utilized drop box of United States Postal Service or delivered such document to a courier or driver authorized by the United States Postal Service. FEDERAL: I declared under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am a member of the State Bar of Texas and have been admitted to practice before this court Pro Hac Vice. Executed on March 9, 2012, at Dallas, Texas.
Exhibit F Page 66
EXHIBIT G TO DECLARATION OF ANDREW W. DeFRANCIS
EXHIBIT G TO DECLARATION OF ANDREW W. DeFRANCIS
KELLEY DRYE & WARREN LLP

10100 SANTA MONICA BOULEVARD TWENTY-THIRD FLOOR LOS ANGELES, CALIFORNIA 90067-4008 TELEPHONE (310) 712-6100 FACSIMILE (310) 712-6199 ANDREW W. DEFRANCIS 310.712.6155 adefrancis(gkelleydrye.com
March 15, 2012 Via Email and U.S. Mail D. Bradley Kizzia Brown Fox Kizzia & Johnson PLLC 8226 Douglas Avenue, Suite 411 Dallas, TX 75225 Re:
Defendants' Responses to NZK Productions Inc.'s Special Interrogatories NZK Productions Inc., et al. v. Stephen Carbone, et al. Central District of California Case No. CV11-10118-GHK (Ex)
Brad: We have received Defendants Stephen Carbone and Reality Steve, LLC's responses to Plaintiff NZK Productions Inc.'s First Set of Special Interrogatories, which were served on March 9, 2012, and they are inadequate in a number of respects. We write to initiate the meet and confer process pursuant to Federal Rule of Civil Procedure 37. Each of the interrogatories discussed below are entirely appropriate, and we suggest that Mr. Carbone and Reality Steve, LLC reconsider their responses and issue supplemental responses to the interrogatories promptly. As you know, both Mr. Carbone and Reality Steve, LLC will be sitting for a deposition concerning their motion to dismiss for personal jurisdiction on April 4, 2012; accordingly, we are on a short timeline. If Mr. Carbone and Reality Steve, LLC refuse to supplement their responses fully, NZK Productions will request an order shortening time to move to compel (or, in the alternative, will request that the Court continue the hearing on Defendants' motion to dismiss for lack of personal jurisdiction so that Plaintiffs may properly defend the challenge). I.
Defendant Stephen Carbone's Responses to Special Interrogatories
First, Defendant Stephen Carbone applies artificial and unfounded limitations to many of his responses. For example, in response to Special Interrogatory No. 1, which requests that Mr. Carbone "[i]dentify all persons who contacted [him] at steve@realitysteve.com concerning the Bachelor Series between January 1, 2004, and the present," Mr. Carbone does not identify a single person who contacted him. Instead, he claims that he "does not recall any names, dates or details of possible communications with California residents years go [sic], but I do not believe I have
Exhibit G Page 67

KELLEY DRYE & WARREN LLP D. Bradley Kizzia March 15, 2012 Page 2
made or received any communications with residents of California about non-public information concerning the Bachelor series since January 1, 2011." There are several problems with this response. First, the persons who contacted Mr. Carbone since January 1, 2004, are readily identifiable by consulting the email address referenced in the interrogatory, for which nothing should have been deleted related to the Bachelor Series since at least last November. Second, the interrogatory does not limit itself to California residents that contacted Mr. Carbone, nor does it limit itself to "non-public information" concerning the Bachelor Series; rather, the interrogatory requests "all persons" who contacted Mr. Carbone "concerning the Bachelor Series." Finally, as seen throughout Mr. Carbone's responses, Mr. Carbone applies a unilateral date restriction on his response, i.e., "since January 1, 2011." NZK Productions requests that Mr. Carbone supplement his response to Special Interrogatory No. 1 forthwith. In addition, several of Mr. Carbone's other interrogatory responses suffer from the same deficiencies, including Nos. 2 (which references the response to No. 1), 3, 4 (which references the response to No. 3), 5, 6 (which references the response to No. 5), 7, 8 (which references the response to No. 7), 12, and 13 (which references the response to No. 12). Accordingly, NZK Productions requests that Mr. Carbone supplement his responses to Special Interrogatory Nos. 2 through 8, 12, and 13, as well. Second, in response to Special Interrogatory No. 10, which asks Mr. Carbone to "[i]dentify each interview [he] gave concerning the Bachelor Series between January 1, 2004, and the present," Mr. Carbone fails to provide any response other than referencing his response to Special Interrogatory No. 9 and adding, "there were various radio interviews, but none in California." This response is unacceptable. The Federal Rules provide for broad discovery, and according to Rule 26(b)(1), "[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense." NZK Productions is entitled to know the date and station that broadcast all of Mr. Carbone's interviews, regardless of whether they occurred in California or not. If those interviews were transmitted in California or were picked up by a national network, for instance, those would certainly impact the Court's ruling on personal jurisdiction. Third, in response to Special Interrogatories Nos. 14, 15, 16, and 17, Mr. Carbone unilaterally limited each of his responses to "since January 1, 2011," when there was no such date limitation on the interrogatories. Although NZK Productions will agree to a date limitation, it will certainly not agree to one in 2011. NZK Productions requests that Mr. Carbone supplement these responses, at least regarding communications since January 1, 2004.
Exhibit G
299238.1.doc
Page 68

D. Bradley Kizzia March 15, 2012 Page 3 Finally, in response to Special Interrogatory No. 18, Mr. Carbone indicates that he "visited California approximately five (5) six (6) times per year from January 1, 2006 through the present," but he fails to provide any additional details. As defined in the Special Interrogatories, the term "identify" means, "as to an event. . . stating its date, the location and the manner of its occurrence, [etc.]." NZK Productions requests that Mr. Carbone provide at least each of the dates that he traveled to and from California since January 1, 2004. As you know, on January 31, 2012, the Court granted Plaintiffs' ex parte application for an order permitting Plaintiffs to conduct jurisdictional discovery, "including but not limited to. . . propounding interrogatories[.]" That said, NZK Productions is particularly concerned about Mr. Carbone's inadequate responses given the upcoming April 4, 2012, deposition on personal jurisdiction. NZK Productions needs complete responses to these Special Interrogatories before that deposition so that it may properly examine Mr. Carbone and oppose Mr. Carbone's motion to dismiss for lack of personal jurisdiction. II.
Defendant Reality Steve, LLC's Responses to Special Interrogatories
Reality Steve, LLC's responses to NZK Productions' First Set of Special Interrogatories are also deficient. For example, in response to Special Interrogatory No. 3, Reality Steve, LLC fails to provide any contact information for the parties that host(ed) www.realitysteve.com , and in response to Special Interrogatory No. 5, it fails to provide any contact information for the parties to or dates of the agreements concerning advertising on www.realitysteve.com . NZK Productions requests that Reality Steve, LLC supplement its response to these two interrogatories, given that the term "identify" is defined in the Special Interrogatories and requires contact information and dates. This information is highly relevant to Defendants' personal jurisdiction objections. In response to Special Interrogatory No. 6, Reality Steve, LLC provides no response. NZK Productions requests that Reality Steve, LLC identify all persons that purchased advertising on www.realitysteve.com between January 1, 2004, and the present, notwithstanding Reality Steve, LLC's comment that "[t]he advertising purchased was only for a two-week period, and none of the advertisers were in California." Those objections certainly do not entitle Reality Steve, LLC to not provide details about anybody who purchased such advertising. NZK Productions similarly requests that Reality Steve, LLC supplement its response to Special Interrogatory No. 9 as it relates to Steve Cook. While Reality Steve, LLC provides contact information for Yea! Networks, LLC and Kris Drouet, it does not provide contact information for Mr. Cook. While a subsequent response later identifies that Reality Steve, LLC's contractual relationship with Mr. Cook ended on February 15,
Exhibit G
299238.1.doc
Page 69

D. Bradley Kizzia March 15, 2012 Page 4 2012 the day NZK Productions served its Requests for Production in this matter that does not permit Reality Steve, LLC to withhold Mr. Cook's contact information. In response to Special Interrogatories Nos. 14 and 15, Reality Steve, LLC indicates that it "do[es] not know" what number of the 2,000,000 visitors to www.realitysteve.com per month visit from California, given that the "email address" of the visitors does not disclose their location. However, location data is easily found in reference to IP tracking logs that webmasters control. NZK Productions requests that Reality Steve, LLC supplement those two responses accordingly. Finally, like Mr. Carbone's responses, Reality Steve, LLC seems to employ the strategies of employing unilateral and unacceptable date limitations and choosing not to answer the interrogatories that were requested. For the reasons set forth above, NZK Productions requests that Reality Steve, LLC supplement its responses to Interrogatories Nos. 21, 22 and 23. Regrettably, as delineated above, both Mr. Carbone's and Reality Steve, LLC's responses compel the conclusion that NZK Productions may need to quickly move to compel supplemental responses if they do not reconsider its positions. However, we hope that we can resolve these matters informally, so please let us know your availability to discuss as soon as possible. Please do not hesitate to call with any questions.
Best Regards,
Andrew W. DeFrancis KELLEY DRYE & WARREN LLP
cc:
Gregg A. Farley (via email) Michael J. O'Connor (via email)
299238.1.doc
Exhibit G Page 70

Plaintiff's 1st Set of Interrogatories For Reality Steve LLC & Steve Carbone

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Case 2:11-cv-10118-GHK-E Document 29-1

Filed 03/26/12 Page 1 of 74 Page ID #:231

EXHIBIT A TO DECLARATION OF ANDREW W. DeFRANCIS

EXHIBIT A TO DECLARATION OF ANDREW W. DeFRANCIS

NOTE: CHANGES MADE BY THE COURT

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

CASE NO. CV11-10118 GHK (Ex)

, 2012, at 9:30 a.m.

In the interim, Plaintiffs are hereby permitted leave of Court to conduct

CV11-10118 GHK (Ex)

Case 2:11-cv-10118-GHK-E Document 29-1

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EXHIBIT B TO DECLARATION OF ANDREW W. DeFRANCIS

EXHIBIT B TO DECLARATION OF ANDREW W. DeFRANCIS

Case 2:11-cv-10118-GHK-E Document 29-1

Filed 03/26/12 Page 5 of 74 Page ID #:235

DEFENDANT STEPHEN CARBONE ONE

Case 2:11-cv-10118-GHK-E Document 29-1

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Case 2:11-cv-10118-GHK-E Document 29-1

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27 Special Interrogatory No. 7.

CV11-10118 GHK (Ex)

Case 2:11-cv-10118-GHK-E Document 29-1

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28 or was a resident of California concerning www.realitysteve.com 298408. I .doc 3

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26 January 1, 2004, and the present. 27 / / / 28

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CV11-10118 GHK (Ex)

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Case 2:11-cv-10118-GHK-E Document 29-1

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EXHIBIT C TO DECLARATION OF ANDREW W. DeFRANCIS

EXHIBIT C TO DECLARATION OF ANDREW W. DeFRANCIS

Case 2:11-cv-10118-GHK-E Document 29-1

Filed 03/26/12 Page 13 of 74 Page ID #:243

DEFENDANT REALITY STEVE, LLC ONE

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The terms "YOU," "YOUR," or "DEFENDANT," as used in these

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26 all income derived from PERSONS who reside in California. 27 / / / 28

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1 SPECIAL INTERROGATORY NO. 25: 2 4 5 DATED: February 7, 2012 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

For each of the PERSONS identified in response to Special Interrogatory No.

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Karen M. jaden --..'

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EXHIBIT D TO DECLARATION OF ANDREW W. DeFRANCIS

EXHIBIT D TO DECLARATION OF ANDREW W. DeFRANCIS

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