Playboy vs. Shidan Gouran - August 1 Supplemental 122

Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 06:52 PM Sherri R.
Carter, Executive Officer/Clerk of Court, by R. Sanchez,Deputy Clerk
1 AKIN GUMP STRAUSS HAUER & FELD LLP

SUSAN K. LEADER (SBN 216743)
2 sleader@akingump.com
BRETT M. MANISCO (SBN 318351)
3 bmanisco@akingump.com
1999 Avenue of the Stars, Suite 600
4 Los Angeles, CA 90067-6022
Telephone: 310.229.1000
5 Facsimile: 310.229.1001
6 Attorneys for Plaintiff and Cross-Defendant
Playboy Enterprises, Inc.
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 FOR THE COUNTY OF LOS ANGELES
10
PLAYBOY ENTERPRISES, INC., a Delaware Case No. BC716374
11 Corporation,
[Assigned To The Honorable Elaine Lu For
12 Plaintiff, All Purposes, Dept. 26]
13 v.
DECLARATION OF BRETT M.
14 GLOBAL BLOCKCHAIN TECHNOLOGIES MANISCO IN SUPPORT OF
CORPORATION, a Canadian corporation; SHIDAN PLAINTIFF PLAYBOY ENTERPRISES,
15 GOURAN, an individual; TOKKEN MSB INC., a INC.’S SUPPLEMENTAL BRIEFING
Canadian corporation; VICE INDUSTRY TOKEN, IN OPPOSITION TO DEFENDANT
16 INC., a California corporation; STUART DUNCAN, STUART DUNCAN’S MOTION TO
an individual; and DOES 1-10 inclusive, DISMISS FOR LACK OF PERSONAL
17 JURISDICTION OR IN THE
Defendants. ALTERNATIVE FORUM NON
18 CONVENIENS
19
20
GLOBAL BLOCKCHAIN TECHNOLOGIES
21 CORPORATION, a Canadian corporation
22 Cross-Complainant,
Date: August 9, 2019
23 vs. Time: 8:30 a.m.
Dept.: 26
24 PLAYBOY ENTERPRISES, INC., a Delaware
corporation; TOKKEN MSB INC., a Canadian
25 corporation; VICE INDUSTRY TOKEN, INC., a
California corporation; STUART DUNCAN, an
26 individual; and ROES 1-10 inclusive,
27 Cross-Defendants. Date Action Filed: August 3, 2018
28
DECLARATION OF BRETT M. MANISCO IN SUPPORT OF PLAINTIFF PLAYBOY ENTERPRISES, INC.’S
SUPPLEMENTAL BRIEFING IN OPPOSITION TO DEFENDANT STUART DUNCAN’S MOTION TO DISMISS FOR
LACK OF PERSONAL JURISDICTION OR IN THE ALTERNATIVE FORUM NON CONVENIENS
1 DECLARATION OF BRETT M. MANISCO
2
I, Brett M. Manisco, declare as follows:
3
1. I am an attorney at Akin Gump Strauss Hauer & Feld LLP, counsel of record for
4
Plaintiff Playboy Enterprises, Inc. (“Playboy”), in Playboy Enterprises, Inc., et al v. Global Blockchain
5
Technologies Corporation, et al. I am an attorney admitted to practice before the Courts of the State of
6
California. I have personal knowledge of the matters set forth in this declaration, and, if called as a
7
witness, could and would testify competently thereto.
8
2. This Declaration is submitted in support of Plaintiff Playboy’s Revised Opposition to
9
Defendant Stuart Duncan’s Motion To Dismiss For Lack Of Personal Jurisdiction Or In The
10
Alternative Forum Non Conveniens.
11
3. After the Court’s hearing on July 30, 2019, I emailed counsel for Stuart Duncan, Paul
12
Katrinak (“Mr. Katrinak”), and asked if he would be willing to stipulate to the authenticity of certain
13
documents that Playboy attached to its Opposition to Mr. Duncan’s Motion to Dismiss that it filed on
14
July 17, 2019. Specifically, I asked him to stipulate as to the authenticity of the following documents:
15
Exhibit 1 - The Statement of Information filed by Vice Industry Token, Inc. with
16
the California Secretary of State, which I retrieved from the California Secretary
17
of State’s website.
18
Exhibit 2 – The Federal Corporation Information Printout from the Government
19
of Canada’s website corresponding to Tokken MSB, Inc.
20
Exhibit 12 – The printout from the United States Patent and Trademark office
21
regarding Mr. Duncan’s ownership of the trademark for the phrase, “Get Paid to
22
Watch Porn.”
23
Exhibit 15 – A copy of the Certificate of Amendment of Articles of
24
Incorporation filed by Vice Industry Token, Inc. with the Secretary of State of
25
California.
26
27
28 1
1 4. Mr. Katrinak responded to me on that same date and agreed that he would not object on
2 the grounds of authenticity to these exhibits. A true and correct copy of my email exchange with Mr.
3 Mr. Katrinak is attached as Exhibit 16.
4 5. On August 1, 2019 at approximately 10:30 a.m., I visited Playboy’s website,
5 www.playboyenterprises.com, and navigated to its “press page” at
6 www.playboyenterprises.com/playboy-news/. From there, I scrolled down to a press release dated
7 March 14, 2018, which was titled, “Playboy Enterprises to Introduce Cryptocurrency Wallet for Use on
8 Its Online Platforms.” A true and correct copy of this press release, which I downloaded from
9 Playboy’s website, is attached hereto as Exhibit 8.
10 6. Akin Gump, on behalf of Playboy, propounded Playboy’s First set of Requests for
11 Production on GBT on August 27, 2018. A true and correct copy of those requests that we served on
12 GBT is attached hereto as Exhibit 17.
13 7. On November 7, 2018, GBT served its written responses to these requests. A true and
14 correct copy of the written responses that were served on Playboy on November 7, 2018 is attached
15 hereto as Exhibit 18.
16 8. Mr. Gouran, in his capacity as the then CEO of GBT, verified the responses to
17 Playboy’s First Set of Requests for Production on November 9, 2018. A true and correct copy of Mr.
18 Gouran’s verification of GBT’s responses to Playboy’s First Set of Requests for Production is attached
20 9. The following documents were received as part of GBT’s verified responses to
21 Playboy’s First Set of Requests for Production:
22 The draft MOU that Mr. Duncan sent to Mr. Gouran on February 5, 2018, which
23 is bates numbered GBT_000089 – GBT_000095.
24 An email exchange between Mr. Duncan and Mr. Gouran on March 8, 2018,
25 which is bates numbered GBT_001396 – GBT_001398.
26 An email exchange between Mr. Duncan, Mr. Gouran, and principles of their PR
27 agencies, which is bates numbered GBT_000370 – GBT_000376.
28 2
1 An email exchange between Mr. Duncan and Mr. Gouran dated March 16, 2018,
2 which is bates numbered GBT_001431.
3 A memo that Mr. Gouran forwarded to Mr. Duncan on March 16, 2018, which is
4 bates numbered GBT_001432.
5 10. A true and correct copy of the aforementioned documents are attached as Exhibits 4, 6,
6 7, 9 and 10 to my declaration.
7 11. Akin Gump, on behalf of Playboy, propounded Playboy’s First set of Special
8 Interrogatories on GBT on August 27, 2018. A true and correct copy of the interrogatories that we
9 served on GBT is attached hereto as Exhibit 20.
10 12. On November 7, 2018, GBT served its written responses to these interrogatories. A true
11 and correct copy of the written responses that were served on Playboy on November 7, 2018 is
12 attached hereto as Exhibit 11.
13 13. Mr. Gouran, in his capacity as the then CEO of GBT, verified the responses to
14 Playboy’s First Set of Special Interrogatories on November 9, 2018. A true and correct copy of Mr.
15 Gouran’s verification of GBT’s responses to Playboy’s First Set of Requests for Production is attached
17 I certify under penalty of perjury under the laws of California that the foregoing is true and
18 correct.
19 Executed on August 1, 2019 at Los Angeles, California.
20
21
Brett M. Manisco
22
23
24
25
26
27
28 3
1.
VICE INDUSTRY TOKEN, INC.
2.
C4096615 This Space for Filing Use Only
(Not applicable if agent address of record is a P.O. Box address. See instructions.)
3.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed .
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE
9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY CITY STATE ZIP CODE
6. MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE
7. EMAIL ADDRESS FOR RECEIVING STATUTORY NOTIFICATIONS
(The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY STATE ZIP CODE
STUART KENNETH DUNCAN 9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
8. SECRETARY ADDRESS CITY STATE ZIP CODE
9. CHIEF FINANCIAL OFFICER/ ADDRESS CITY STATE ZIP CODE
LARRY PAGET 9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
(The corporation must have at least one
director. Attach additional pages, if necessary.)
10. NAME ADDRESS CITY STATE ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: 0

If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
STEPHEN MICHAEL KERNAN
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, CITY STATE ZIP CODE
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION

CRYPTOCURRENCY PROPRIETOR
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/19/2018 STEPHEN MICHAEL KERNAN ATTORNEY
DATE TYPE/PRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE
SI-200 (REV 01/2013) APPROVED BY SECRETARY OF STATE
1 RAINES FELDMAN LLP
Laith D. Mosely (Bar No. 250832)
2 lmosely@raineslaw.com
Lawrence J.H. Liu (Bar No. 312115)
3 lliu@raineslaw.com
18401 Von Karman Ave., Suite 360
4 Irvine, California 92612
Telephone: (310) 440-4100
5 Facsimile: (310) 449-4877
6 Attorneys for Defendant, Global Blockchain Technologies Corporation, a Canadian

corporation
7

9 COUNTY OF LOS ANGELES CENTRAL DISTRICT
10
11 PLAYBOY ENTERPRISES, INC., a Case No. BC716374

Delaware Corporation,
12 Assigned to for All Purposes to:
13 Plaintiff, Hon. Susan Bryant-Deason, Dept. 52
14 vs.
15 DEFENDANT GLOBAL
GLOBAL BLOCKCHAIN BLOCKCHAIN TECHNOLOGIES
16 TECHNOLOGIES CORPORATION, a RESPONSES TO
Canadian corporation; and DOES 1-10, PLAINTIFF PLAYBOY
17
INTERROGATORIES, SET ONE
18 Defendants.
19
20
Complaint filed: August 3, 2018
21
PROPOUNDING PARTY: Plaintiff Playboy Enterprises, Inc.
22
RESPONDING PARTY: Defendant Global Blockchain Technologies Corporation
23
SET NO.: ONE
24
25
Pursuant to California Code of Civil Procedure sections 2030.010 et seq., Defendant
26
27
undersigned counsel, responds and objects to Plaintiff Playboy Enterprises,
28
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DEFENDANT GBT RESPONSES
1 First Set of Special Interrogatories
2 on Defendant GBT.
3 PRELIMINARY STATEMENT
4 These responses are made solely for the purpose of this action. Each answer is
5 subject to all objections as to competence, relevance, materiality, propriety and
6 admissibility, and any and all other objections and grounds which would require the
7 exclusion of any statement herein if the Interrogatories were asked of, or any statements
8 contained herein were made by, a witness present and testifying in Court, all of which
9 objections and grounds are reserved and may be interposed at the time of trial.
10 Responding Party has not completed its investigation of the facts relating to this
11 case and has not completed its preparation for trial. The following responses are based
12 upon information presently available and known to Responding Party and are made
13 without prejudice to Responding Party of the right to rely upon other or subsequently
14 discovered facts, documents, and witnesses.
15 Except for explicit facts admitted herein, no incidental or implied admissions are
16 intended hereby. The fact that Responding Party has answered any interrogatory should
17 not be taken as an admission that Responding Party accepts or admits the existence of any
18 facts set forth or assumed by such interrogatory, or that such response constitutes
19 admissible evidence. The fact that Responding Party has answered part or all of any
20 interrogatory is not intended and shall not be construed to be a waiver by Responding
21 Party of all or any part of any objection to any interrogatory made by Propounding Party.
22 The Preliminary Statement is incorporated into each of the responses set forth
23 below.
24 GENERAL OBJECTIONS
25
1. Responding Party objects to the Interrogatories to the extent they
26
purport to expand Responding Party's discovery obligations beyond those established
27
by the California Rules of Civil Procedure and the applicable rules of this Court.
28
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1 2. Responding Party objects to the Interrogatories to the extent they seek
2 materials or information that are neither relevant to any claim or defense in this
3 case, nor reasonably calculated to lead to the discovery of admissible evidence.

5 materials or information that are not in Responding Party's possession, custody, or
6 control.

8 materials or information that are (l) already in Propounding Party's possession, custody,
9 or control; (2) equally or more readily available to Propounding Party; (3) publicly
10 available; or (4) obtainable from other sources or through other means of discovery
11 that are more convenient, more efficient, more practical, less burdensome, or less
12 expensive.

14 materials or information shielded from disclosure by the attorney-client privilege, the
15 work- product doctrine, or any other applicable privilege or protection. Responding
16 Party's responses to the Interrogatories do not waive, and may not be construed as
17 waiving, any applicable objection, privilege, or protection. Inadvertent disclosure of
18 information subject to a claim of privilege or protection is not, and may not be
19 deemed, a waiver of that privilege or protection. Unless otherwise stated, Responding
20 Party will neither log nor produce any materials generated subsequent to Propounding
21 Party's filing of this lawsuit against Responding Party (including in connection with these
22 objections and responses), even if they would otherwise be responsive to the literal terms of
23 a request, given the undue burdens and lack of relevance associated with any such
24 materials.
25 6. To the extent that any Interrogatory or response implicates Responding

26 Party's confidential business or customer information, Responding Party reserves the
27 right to designate such information as needed under a protective order.
28
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1 7. Responding Party objects, to Interrogatories calling for information not
2 reasonably accessible without undue burden and/or cost. Responding Party reserves the
3 right to search and, if appropriate, produce responsive, non-privileged information from
4 such sources only if Propounding Party agrees to shift costs associated with such search
5 and response.
6 8. Responding Party's election to respond to an Interrogatory, notwithstanding

7 the objectionable nature of that Interrogatory, is not: (a) an acceptance of, or agreement
8 with, any of the characterizations or purported descriptions of the transactions or
9 events contained in the Interrogatory; (b) a concession or admission that the materials are
10 relevant to this proceeding; (c) a waiver of the general objections or the objections asserted
11 in response to that specific Interrogatory; (d) an admission that any such information
12 or documents exist; (e) an agreement that requests for similar information or documents
13 will be treated in a similar manner; or (f) an acceptance of, or agreement with, any of the
14 definitions in the Interrogatories to the extent that the definition or meaning of any
15 defined term is at issue in this action.
16 9. Responding Party reserves the right to amend, supplement, or alter these

17 objections and responses at any time if it becomes necessary or appropriate to do so.
18 These objections and responses are made without prejudice to, and are not a waiver of,
19 Responding Party's right to rely on other facts or documents.
20 The General Objections are incorporated into each of the responses set forth below.
21 SPECIAL INTERROGATORIES
22 SPECIAL INTERROGATORY NO. 1:
23 Describe, with particularity, any dealings, discussions, or interactions between VIT

24 and PLAYBOY relating to the MOU, including, without limitation, identifying all
25 PERSONS with knowledge regarding this topic.
26 (As used h
27 subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants,
28 representatives, directors, officers, employees, experts, independent contractors, and any
-4-
1 other person or entity associated with any of the above individuals or entities, and any
2 other person acting or purporting to act on its behalf.)
4 parents, subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants,
5 representatives, directors, officers, employees, experts, independent contractors, and any
6 other person or entity associated with any of the above individuals or entities, and any
7 other person acting or purporting to act on its behalf.)
9 between PLAYBOY and YOU dated March 13, 2018.)
10
11 Blockchain Technologies Corporation, its parents, subsidiaries, affiliates, attorneys,
12 paralegals, agents, accountants, consultants, representatives, directors, officers, employees,
13 experts, independent contractors, and any other person or entity associated with any of the
14 above individuals or entities, and any other person acting or purporting to act on its
15 behalf.)
16
17 to corporations, partnerships, trusts, entities, or other associations.)
18 RESPONSE TO SPECIAL INTERROGATORY NO. 1:
19 Responding Party objects on the basis that the interrogatory is vague as to time,
20 overbroad, unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020, 2019.030,
21 subd. (a).) Responding Party objects on the basis that the information requested is neither
22 relevant to the subject matter of the litigation nor reasonably calculated to lead to the
23 discovery of admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party
24 objects on the basis that the phrases and terms any dealings, discussions, or interactions
25
26 unintelligible. Responding Party also objects on the basis that the information sought is
27 cords and files. (Code Civ. Proc., § 2019.030,

28 subd. (a)(1).) Responding Party further objects on the basis that the interrogatory as
-5-
1 phrased is compound. (Code Civ. Proc., § 2030.060, subd. (f).) Responding Party further
2 objects to the extent that the interrogatory calls for information protected under attorney-
3 client privilege and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
4 Subject to and without waiving the aforementioned objections, Responding Party

5 responds: VIT is a third-party to the MOU between GBT and Playboy. VIT contracted
6 with GBT to integrate blockchain platform and cryptographic token with Playboy
7 online media platform by developing a digital wallet that could enable VIT cryptocurrency
8 payments through Playboy.t . In discussions with GBT, Playboy

9 indicated that it would seek to obtain management positions in VIT and assist with the
10 technical aspects of the integration.
11 Playboy, however, failed to

12 offer any meaningful support or cooperation with VIT to implement the technologies that
13 it promised. Playboy was also required to provide VIT with additional marketing support
14 and assist with the rebranding efforts. Persons with knowledge include: Shidan Gouran;
15 David DesLauriers; Aaron Rotenberg; Maxwell Arnold; Barry Rotenberg; Reena Patel;
16 Ben Kohn; Rachel Sagan; Jared Dougherty; John Vlautin; Stuart Duncan.
18 Describe, with particularity, the reason(s) why YOU did not make the payment to
19 PLAYBOY of $4,000,000, in cash or stock, by July 16, 2018, including, without
20 limitation, identifying all PERSONS with knowledge regarding this topic.
22 This interrogatory incorrectly assumes that the MOU is a binding agreement or

23 promise. Responding Party objects on the basis that the interrogatory is vague as to time,
25 subd. (a).)
26 undefined and so vague and ambiguous to the extent that the interrogatory is unintelligible.
27 Responding Party also objects on the basis that the interrogatory as phrased is compound.
28 (Code Civ. Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent
-6-
1 that the interrogatory calls for information protected under attorney-client privilege and/or
2 the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

4 responds: Following the execution of the MOU, GBT relied on Playboy to provide
5 backend technical support and to cooperate with Vice Industry Token in promoting the
6 business venture. Playboy provided no support or collaborative effort until the Crowdsale
7 was long over. Playboy made no contact with, nor any attempt to work with VIT on
8 In addition, Playboy did not attempt to

9 meet and negotiate the long form agreement in a reasonable time as required under the
10 MOU. Ultimately, Playboy failed to engage with GBT and VIT to provide the support as
11 promised under the terms of the MOU until long after the Crowdsale had finished and
12 when such support had little to no impact on promoting the venture among the parties.
13 Instead, Playboy sought to obtain a windfall by demanding the $4,000,000 from the
14 Crowdsale, which it did not participate in, and based on the non-binding terms of the
15 MOU, which had not yet been finalized and were subject to various future conditions that
16 had not yet been met and further negotiations between the parties. GBT has acted in good
17 faith by seeking to continue discussions with Playboy regarding the live tv and
18 marketplace proposal options which was originally intended by the parties. Playboy,
19 however, has rebuffed such requests for further discussions.
21 Describe, with particularity, the technical support that YOU provided to

22 PLAYBOY, including, without limitation, identifying all PERSONS with knowledge
23 regarding this topic.
-7-
2 objects on the basis that the terms undefined and

3 so vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
4 Party also objects on the basis that the information sought is obtainable from Propounding
6 Party further objects on the basis that the interrogatory as phrased is compound. (Code Civ.
7 Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent that the
8 interrogatory calls for information protected under attorney-client privilege and/or the
9 work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

11 responds: GBT was effectively prevented from providing any technical support to Playboy
12
13 Individuals with knowledge include: Shidan Gouran; David

14 DesLauriers; Aaron Rotenberg; Maxwell Arnold; Barry Rotenberg; Stuart Duncan.
16 Describe, with particularity, all changes YOU made to the VIT website relating to
17 PLAYBOY or the MOU, including, without limitation, identifying all PERSONS with
18 knowledge regarding this topic.
25 , undefined and
27 Party further objects on the basis that the interrogatory as phrased is compound. (Code Civ.
28 Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent that the
-8-
1 interrogatory calls for information protected under attorney-client privilege and/or the
3 Without waiving the aforementioned objections, Responding Party responds: GBT

4 did not actually make any changes to third p which is in the sole
5 control of VIT and/or Tokken MSB. However, on March 13, 2018, GBT requested that
6 VIT make the following changes on its website:
7 c
8
10 remove all references

11
12
13 change the language o The Vice Industry Token

14 represents a profound change in the broadcast and on-demand video
15 entertainment industry. It functions as two things; a video entertainment
16 platform where viewers can watch videos, and as a cryptocurrency where
17 anybody who participates (in viewing, adding, or curating content) will get paid
18 with VIT's proprietary cryptocurrency.
19
20 The original paradigm in mainstream and adult entertainment was that people
21 paid for the content they consumed; whether by subscription or pay-per-view.
22 With "tube" websites becoming popular, there was a shift toward free-viewing.
23 While free content was certainly desirable, wouldn't it be better if you could get
24 paid for it, too?
25
26 Vice Industry Token is creating a breakthrough in the online video

27 entertainment industry where everybody who accesses the platform will be
28 rewarded. This includes producers, distributors, and more importantly... you as
-9-
1 the viewer.
2
3 Backed by some of the top names in the entertainment world, Vice Industry
4 Token will deliver you the content that you want to see, while enabling you to
5 get paid just for watching it.
6
7 Online entertainment is a multi-billion dollar industry. Vice Industry Token is

8 your opportunity to get a piece of it, and all you have to do is watch videos. It's
9 that simple. Sit back and watch as we revolutionize mainstream and adult
10 entertainment. We look forward to you joining us! ;
11
12 make changes to the affiliate partners section.

13
14 Persons with knowledge include Shidan Gouran, Mike Koroshun, Jared Dougherty,
15 Reena Patel, and Stuart Duncan.
17 Describe, with particularity, the amount and nature of YOUR funds at the time
18 YOU entered into the MOU, including, without limitation, identifying all PERSONS with
21 Responding Party objects on the basis that the interrogatory is vague, overbroad,
22 unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020, 2019.030, subd. (a).)
23 Responding Party objects on the basis that the information requested is neither relevant to
24 the subject matter of the litigation nor reasonably calculated to lead to the discovery of
25 admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party objects on the basis
26
27 order. (Civ. Code, § 3295; Kerr v. Rose (1990) 216 Cal.App.3d 1551, 1565; Jabro v.
28 Superior Court (2002) 95 Cal.App.4th 754, 758.) Responding Party objects on the basis
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1 that the phrases amount and nature of YOUR funds are so vague and
2 ambiguous to the extent that the interrogatory is unintelligible. Responding Party further
3 objects on the basis that the interrogatory as phrased is compound. (Code Civ. Proc., §
4 2030.060, subd. (f).) Responding Party further objects to the extent that the interrogatory
5 calls for information protected under attorney-client privilege and/or the work product
6 doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
7 The interrogatory necessitates the preparation of a compilation, abstract, audit or

8
9 be similarly burdensome and/or expensive to both propounding and responding parties.
10 (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of California (1962) 57 Cal.2d
11 287.) Subject to and without waiving the aforementioned objections, Responding Party
12 responds: The information re
13
14 Request for Production of Documents and Things, Set One.
16 Describe, with particularity, the cash proceeds that YOU received from the
17 CROWDSALE, including, without limitation, identifying all PERSONS with knowledge
18 regarding this topic.
19
20 in the MOU which was held from February 20, 2018 to March 20, 2018.)
27
28 permitted without a court order. (Civ. Code, § 3295; Kerr v. Rose, supra, 216 Cal.App.3d
-11-
1 at 1565; Jabro v. Superior Court, supra, 95 Cal.App.4th at 758.) Responding Party objects
3 vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
4 Party further objects to the extent that the interrogatory calls for information protected
5 under attorney-client privilege and/or the work product doctrine. (Code Civ. Proc., §§
6 2018.010 et seq.) The interrogatory necessitates the preparation of a compilation, abstract,
7 sion, and such

8 preparation would be similarly burdensome and/or expensive to both propounding and
9 responding parties. (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of
10 California (1962) 57 Cal.2d 287.)
11 Based on these objections, Responding Party is unable to respond to this

12 interrogatory, however, invites Propounding Party to further meet and confer regarding the
13 information requested.
15 Describe, with particularity, what YOU did with the cash proceeds that YOU
16 received from the CROWDSALE, including, without limitation, identifying all PERSONS
17 with knowledge regarding this topic.
24
25 permitted without a court order. (Civ. Code, § 3295; Kerr v. Rose (1990) 216 Cal.App.3d
26 1551, 1565; Jabro v. Superior Court (2002) 95 Cal.App.4th 754, 758.) Responding Party
27
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1 Responding Party further objects to the extent that the interrogatory calls for information
2 protected under attorney-client privilege and/or the work product doctrine. (Code Civ.
3 Proc., §§ 2018.010 et seq.) The interrogatory necessitates the preparation of a compilation,
5 preparation would be similarly burdensome and/or expensive to both propounding and
6 responding parties. (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of
7 California (1962) 57 Cal.2d 287.)
8 Based on these objections, Responding Party is unable to respond to this

9 interrogatory, however, invites Propounding Party to further meet and confer regarding the
10 information requested.
12 DESCRIBE, with particularity, Shidan Gouran s authority to promise, on YOUR

13 behalf, that YOU would provide stock to PLAYBOY in the event the CROWDSALE
14 raised less than $4,000,000, including, without limitation, identifying all PERSONS with
15 ·knowledge regarding this topic.
17 This interrogatory incorrectly assumes that the MOU is a binding agreement or

18 promise. Responding Party objects on the basis that the interrogatory is vague as to time,
19 overbroad, cumulative, unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020,
20 2019.030, subd. (a).) Responding Party objects on the basis that the information requested
21 is neither relevant to the subject matter of the litigation nor reasonably calculated to lead to
22 the discovery of admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party
23
24 vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
25 Party also objects on the basis that the interrogatory is not full and complete in and of
26 itself, and instead, Responding Party must resort to other materials in order to respond to
27 the interrogatory. (Code Civ. Proc., § 2030.060, subd. (d); Catanese v. Superior Court,
28 supra, 46 Cal.App.4th at 1164.) Responding Party further objects on the basis that the
-13-
1 interrogatory as phrased is compound. (Code Civ. Proc., § 2030.060, subd. (f).)
2 Responding Party further objects to the extent that the interrogatory calls for information
4 Proc., §§ 2018.010 et seq.)
5 Without waiving the aforementioned objections, Responding Party responds:

6 Shidan Gouran is the CEO of GBT. Persons with knowledge include: all employees,
7 directors, and officers of GBT.
9 Dated: November 7, 2018 RAINES FELDMAN LLP

10
11
By:
12 Laith D. Mosely
Lawrence J.H. Liu
13 Attorneys for Defendant, Global
Blockchain Technologies Corporation, a
14
Canadian corporation
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-14-
From: Paul Katrinak
To: Manisco, Brett
Cc: Leader, Susan
Subject: Re: Protective Order and Stipulations re Exhibits
Date: Tuesday, July 30, 2019 4:24:43 PM
**EXTERNAL Email**
Agreed. I will stipulate to authenticity of those specific documents.
On Tue, Jul 30, 2019 at 1:54 PM Manisco, Brett <bmanisco@akingump.com> wrote:
Paul,
Thank you for agreeing to and complying with the terms of the protective order entered into
on Dec. 6, 2018 (attached for your convenience). This email also serves as confirmation
that you’ve received Playboy’s production via the flash drive I handed to you in court
today.
Per the court’s suggestion, we wanted to meet and confer with you regarding your
foundational objections to the following exhibits:
Exhibit 1, the Statement of Information filed by Vice Industry Token, Inc. with the
California Secretary of State, which corresponds with your Objection Number 7;
Exhibit 2, the Federal Corporation Information Printout from the Government of
Canada’s website corresponding to Tokken MSB, Inc, which corresponds to your
Objection Number 8;
Exhibit 12, the printout from the United States Patent and Trademark office regarding
Mr. Duncan’s ownership of the trademark for the phrase, “Get Paid to Watch Porn,”
which corresponds to your Objection Number 18.
Exhibit 15, the copy of the Certificate of Amendment of Articles of Incorporation
filed by Vice Industry Token, Inc. with the Secretary of State of California, which
corresponds to your Objection Number 21.
We understand that you preserve all other objections to these exhibits, including relevance,
but just wanted to confirm that you would be willing to stipulate as to authenticity of the
exhibits.
Please let us know by COB today so we can apprise the court of your position.
Thanks,
Brett
Brett M. Manisco
1999 Avenue of the Stars | Suite 600 | Los Angeles, CA 90067-6022 | USA | Direct: +1 310.229.1086 | Internal:
41086
Fax: +1 310.229.1001 | bmanisco@akingump.com | akingump.com | Bio
The information contained in this e-mail message is intended only for the personal and
confidential use of the recipient(s) named above. If you have received this communication in
error, please notify us immediately by e-mail, and delete the original message.
--
Paul Katrinak
The Kernan Law Firm
9663 Santa Monica Blvd., 450
Beverly Hills, California 90210
Tel: (323) 802-1741
Fax: (310) 861-0503
The information contained in this e-mail is intended only for the personal and confidential use of the designated
recipient(s) named above. This message may be an attorney-client communication and, as such, is privileged and
confidential. If the reader of this message is not the intended recipient, you are hereby notified that you have
received this communication in error, and that any review, dissemination, or copying of this message is strictly
prohibited. If you have received this communication in error, please notify us immediately by telephone and delete
the original message. Thank you.
ANDREW S. JICK (SBN 278943)
3 ajick@akingump.com
Telephone: 310.229.1000
5 Facsimile: 310.229.1001
6 Attorneys for Plaintiff
7

11
PLAYBOY ENTERPRISES, INC., a Case No. BC716374
12 Delaware Corporation,
13 Plaintiff,
PLAINTIFF PLAYBOY ENTERPRISES, INC.’S
14 v. REQUESTS FOR PRODUCTION OF
DOCUMENTS AND THINGS TO DEFENDANT
15 GLOBAL BLOCKCHAIN GLOBAL BLOCKCHAIN TECHNOLOGIES
TECHNOLOGIES CORPORATION, a CORPORATION, SET ONE
16 Canadian Corporation; and DOES 1-10,
inclusive,
17
Defendants.
18 Date Action Filed: August 3, 2018
19
20 PROPOUNDING PARTY: Plaintiff Playboy Enterprises, Inc.

21 RESPONDING PARTY: Defendant Global Blockchain Technologies Corporation
22 SET NO: One
23
24
25
26
27
28
PLAINTIFF PLAYBOY ENTERPRISES, INC.’S REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
TO DEFENDANT GLOBAL BLOCKCHAIN TECHNOLOGIES CORPORATION, SET ONE
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that, pursuant to California Code of Civil Procedure sections
3 2031.010. et seq., Plaintiff Playboy Enterprises, Inc. (“PLAYBOY”) hereby requests that Defendant
4 Global Blockchain Technologies Corporation (“YOU” or “YOUR”) respond to the following First Set
5 of Requests for Production of Documents and Things and produce at the office of Akin Gump Strauss
6 Hauer & Feld LLP, located at 1999 Avenue of the Stars, Suite 600, Los Angeles, California 90067, 30
7 days after the date of service hereof, the following documents:
8 INSTRUCTIONS
9 1. These requests call for all DOCUMENTS, COMMUNICATIONS, and tangible things
10 in YOUR actual or constructive possession, custody, or control, or in the actual or constructive
11 possession, custody, or control of YOUR attorneys, auditors, agents, employees, officers, directors, or
12 representatives, or other persons acting under PLAINTIFF’S authorization, employment, or direction,
13 irrespective of who generated, prepared, maintains, or signed the DOCUMENTS or
14 COMMUNICATIONS.
15 2. If any claim of privilege or work product is asserted with respect to any DOCUMENT
16 or COMMUNICATION, the identification of which is called for by any request herein, identify each
17 such DOCUMENT or COMMUNICATION by stating the following information with respect to each
18 such DOCUMENT or COMMUNICATION:
19 a) a description of the type of DOCUMENT or COMMUNICATION (e.g., letter,
20 memorandum, report);
21 b) the subject matter of the DOCUMENT or COMMUNICATION, with sufficient
22 particularity to enable it to be identified and to explain the privilege asserted;
23 c) the basis upon which a privilege or work product is being claimed;
24 d) the date of preparation of the DOCUMENT or COMMUNICATION;
25 e) the number of pages of the DOCUMENT or COMMUNICATION;
26 f) the identity of each person who prepared the DOCUMENT or
27 COMMUNICATION;
28
1
1 g) the identity of each person who signed the DOCUMENT or COMMUNICATION,
2 and each person on behalf of whom such DOCUMENT or COMMUNICATION
3 was signed, if such DOCUMENT or COMMUNICATION was signed on behalf of
4 another person;
5 h) the identity of each person who originated, circulated, or published such
6 DOCUMENT or COMMUNICATION, or on whose behalf such DOCUMENT or
7 COMMUNICATION was originated, circulated or published;
8 i) the name and address of each person who was an addressee thereof, or to whom
9 such DOCUMENT or COMMUNICATION or copy of such DOCUMENT or
10 COMMUNICATION was sent, to whom the DOCUMENT or COMMUNICATION
11 was read or summarized, or who otherwise was aware of the contents of the
12 DOCUMENT or COMMUNICATION;
13 j) the identity of each person presently in possession, custody, or control of such
14 DOCUMENT or COMMUNICATION, or any carbon copy, reproduction, or
15 facsimile thereof; and; (k) the paragraph or paragraphs of these requests to which
16 the DOCUMENT or COMMUNICATION is responsive.
17 3. The production by one person, party, or entity of a DOCUMENT or
18 COMMUNICATION does not relieve another person, party, or entity from the obligation to produce
19 his, her, or its own copy or copies of that DOCUMENT or COMMUNICATION, even if the
20 DOCUMENTS or COMMUNICATIONS are identical.
21 4. DOCUMENTS and COMMUNICATIONS shall be produced as they are kept in the
22 usual course of business. All DOCUMENTS and COMMUNICATIONS shall be produced with a copy
23 of the file folder, envelope, or other container in which the DOCUMENTS or COMMUNICATIONS
24 are kept or maintained. All DOCUMENTS and COMMUNICATIONS shall be produced without
25 disturbing the organization of DOCUMENTS and COMMUNICATIONS as they are kept in the
26 ordinary course of business and during the subsequent maintenance of the DOCUMENTS and
27 COMMUNICATIONS.
28
2
1 5. If you assert an objection to any request, you must nonetheless respond and produce any
2 responsive DOCUMENTS or COMMUNICATIONS that are not subject to the stated objection. If you
3 object to part of a request or category, you must specify the portion of the request to which you object,
4 and must produce DOCUMENTS and COMMUNICATIONS responsive to the remaining parts of the
5 request.
6 6. If any DOCUMENT or COMMUNICATION described in these Requests was, but no
7 longer is, in YOUR or YOUR agents’ possession, custody, or control, state in writing whether:
8 a) it is missing or lost;
9 b) it has been destroyed;
10 c) it has been transferred voluntarily or involuntarily to others; or
11 d) it has been disposed of otherwise.
12 In each instance, explain the circumstances surrounding such disposition and identify the person(s)
13 directing or authorizing same and the date(s) thereof. Identify each DOCUMENT or
14 COMMUNICATION by listing its author, his or her address, type (e.g., letter, memorandum, telegram,
15 chart, photograph, electronic mail), date, subject matter, present locations(s) and custodian(s).
16 7. Electronically stored information (“ESI”), including all applicable DOCUMENTS and
17 COMMUNICATIONS, shall be produced in native format as provided below:
18 a) DOCUMENTS and COMMUNICATIONS shall display the Bates number(s) in the
19 filename of the native file.
20 b) A Concordance formatted delimited file with a “.dat” file containing the following
21 metadata fields shall be provided: BEGINBATES, ENDBATES, BEGINGROUP,
22 ENDGROUP, PAGECOUNT, ITEMPATH, TEXTPATH, PDFPATH,
23 ITEMCATEGORY, ITEMDATE, DATE, TIME, NAME (or SUBJECT), AUTHOR,
24 FROM, TO, CC, BCC, MD5DIGEST, ATTACHMENTS, PATHNAME,
25 FILETYPE, FILESIZE, CUSTODIAN.
26 DEFINITIONS
27 1. The term “COMMUNICATION” shall mean the transmittal, conveyance,
28 dissemination, or delivery of information in any manner, including but not limited to text message,
3
1 electronic message (e.g., email, email attachment, instant message), telephone conversation, face-to-
2 face meeting or conversation, visit, inquiry, request, conference, internal or external discussion, or
3 exchange of DOCUMENT(s). COMMUNICATION shall also include any response to a
4 COMMUNICATION or DOCUMENT.
5 2. The term “DOCUMENT” shall be defined as in Evidence Code § 250, including any
6 printed, typewritten, handwritten, graphic, or records matter of whatever character, including but not
7 limited to letters, memoranda, emails, email attachments, receipts, telegrams, writings, recordings,
8 photographs, drawings, graphs, charts, computer records, electronic files (e.g., stored on computer
9 disks, computer hard drives, portable data drives (e.g., thumb drive, flash drive, USB drive, CD, DVD,
10 or otherwise), cloud storage, or otherwise), electronic or computerized data compilations,
11 correspondence, agreements, contracts, notes, instructions, reports, financial statements, demands,
12 data, schedules, notices, work papers, drafts, records, videotapes, charts, analyses, interoffice or
13 intercompany communications, presentations, decks, notebooks, diaries, daily logs, appointment
14 calendars, sketches, plans, written summaries, agendas, check stubs, computer printouts, specifications,
15 blue prints, diagrams, forms, manuals, brochures, lists, publications, minutes of meetings (electronic or
16 hard copy), journals, ledgers or other financial records, invoices, work tickets, purchase orders,
17 cancelled checks, and all other written or graphic material of any nature whatsoever. A draft or non-
18 identical copy of any DOCUMENTS requested herein is a separate DOCUMENT within the meaning
19 of this term.
20 3. The word “all” shall be construed to include both the collective and the singular, and
21 shall mean “each,” “any,” and “every.”
22 4. The terms “REGARDING,” “RELATING TO,” and “RELATED TO” shall mean
23 RELATING TO, referring to, describing, reflecting, concerning, evidencing, demonstrating,
24 constituting, or bearing some logical or factual relationship to.
25 5. The words “YOU” and “YOUR” shall refer to Defendant Global Blockchain
26 Technologies Corporation, its parents, subsidiaries, affiliates, attorneys, paralegals, agents,
27 accountants, consultants, representatives, directors, officers, employees, experts, independent
28
4
1 contractors, and any other person or entity associated with any of the above individuals or entities, and
2 any other person acting or purporting to act on its behalf.
3 6. The terms “and” and “or” shall be construed either disjunctively or conjunctively as
4 necessary to bring within the scope of these Requests any DOCUMENTS which might otherwise be
5 construed to be outside their scope. Whenever appropriate in these Requests, the singular form of a
6 word shall be interpreted as plural, and vice versa.
7 7. The term “PLAYBOY” shall refer to Playboy Enterprises, Inc., and its parents,
8 subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants, representatives,
9 directors, officers, employees, experts, independent contractors, and any other person or entity
10 associated with any of the above individuals or entities, and any other person acting or purporting to
11 act on its behalf.
12 8. The term “ACTION” shall refer to the instant lawsuit filed in Los Angeles Superior
13 Court on August 3, 2018 (Case No. BC716374).
14 9. The term “MOU” refers to the Memorandum of Understanding between PLAYBOY and
15 YOU dated March 13, 2018, a copy of which is attached to the REQUESTS FOR ADMISSION as
16 Exhibit 1.
17 10. The term “VIT” shall refer to Vice Industry Token, Inc., its parents, subsidiaries,
18 affiliates, attorneys, paralegals, agents, accountants, consultants, representatives, directors, officers,
19 employees, experts, independent contractors, and any other person or entity associated with any of the
20 above individuals or entities, and any other person acting or purporting to act on its behalf.
21 11. The term “VICE TOKEN” shall refer to the Vice Industry Token cryptocurrency and
22 related technology.
23 12. The term “CROWDSALE” shall refer to the Crowdsale referenced in the MOU which
24 was held from February 20, 2018 to March 20, 2018.
25 13. The term “REQUESTS FOR ADMISSION” shall refer to the Requests for Admission,
26 Set One, that PLAYBOY served on GBT in this action.
27 14. The term “INTERROGATORIES” shall refer collectively to the Special Interrogatories,
28 Set One, and the Form Interrogatories, Set One, that PLAYBOY served on GBT in this action.
5
1 REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS
2 REQUEST FOR PRODUCTION NO. 1:
3 All DOCUMENTS and COMMUNICATIONS relating to PLAYBOY.
5 All COMMUNICATIONS between YOU and PLAYBOY.
7 All COMMUNICATIONS between Shidan Gouran and PLAYBOY.
9 All COMMUNICATIONS between Shidan Gouran and any other person or entity regarding
10 PLAYBOY.
12 All DOCUMENTS and COMMUNICATIONS relating to the MOU.
14 All drafts of the MOU.
16 All COMMUNICATIONS between Shidan Gouran and any other person or entity relating to
17 the MOU.
19 All DOCUMENTS and COMMUNICATIONS relating to VIT.
21 All DOCUMENTS and COMMUNICATIONS relating to VIT’s dealings, discussions, or
22 interactions with PLAYBOY.
24 All DOCUMENTS and COMMUNICATIONS relating to VIT’s involvement in or with the
25 MOU.
27 All COMMUNICATIONS between YOU and VIT regarding the MOU.
28
6
2 All COMMUNICATIONS between YOU and VIT regarding PLAYBOY.
4 All COMMUNICATIONS between YOU and VIT regarding the ACTION.
6 All COMMUNICATIONS between Shidan Gouran and VIT regarding the MOU.
8 All COMMUNICATIONS between Shidan Gouran and VIT regarding PLAYBOY.
10 All COMMUNICATIONS between Shidan Gouran and VIT regarding the ACTION.
12 All COMMUNICATIONS between YOU and Stephen Michael Kernan, or any other principal,
13 agent, or representative of The Kernan Law Firm, including, but not limited to, any retainer agreements
14 or invoices.
16 All COMMUNICATIONS between Shidan Gouran and Stephen Michael Kernan, or any other
17 principal, agent, or representative of The Kernan Law Firm, including, but not limited to, any retainer
18 agreements or invoices.
20 All DOCUMENTS and COMMUNICATIONS relating to the VICE TOKEN.
22 All DOCUMENTS and COMMUNICATIONS relating to the $4,000,000 cash payment that
23 YOU promised to make to PLAYBOY.
25 All DOCUMENTS and COMMUNICATIONS relating to YOUR failure to make the
26 $4,000,000 cash payment that YOU promised to make to PLAYBOY.
27
28
7
2 All DOCUMENTS and COMMUNICATIONS relating to YOUR promise to provide technical
3 support to PLAYBOY.
5 All DOCUMENTS and COMMUNICATIONS relating to the technical support, if any, that
6 YOU provided to PLAYBOY.
8 All DOCUMENTS and COMMUNICATIONS relating to VIT’s website.
10 All DOCUMENTS and COMMUNICATIONS relating to YOUR promise to remove references
11 to “porn” from the VIT website.
13 All DOCUMENTS and COMMUNICATIONS relating to YOUR removal, if any, of references
14 to “porn” from the VIT website.
16 All DOCUMENTS and COMMUNICATIONS relating to YOUR promise to “rebrand” the VIT
17 website.
19 All DOCUMENTS and COMMUNICATIONS relating to YOUR rebranding, if any, of the VIT
20 website.
22 All DOCUMENTS and COMMUNICATIONS relating to YOUR removal, if any, of the words
23 “Get Paid to Watch Porn” from the VIT website.
25 All DOCUMENTS and COMMUNICATIONS relating to YOUR subsequent reintroduction of
26 the words “Get Paid to Watch Porn” to the VIT website.
27
28
8
2 All DOCUMENTS and COMMUNICATIONS relating to any changes made to the VIT
3 website after YOU entered into the MOU.
5 All DOCUMENTS and COMMUNICATIONS relating to YOUR reference to the service as
6 “adult” content on the VIT website.
8 All DOCUMENTS and COMMUNICATIONS relating to YOUR display of PLAYBOY’s
9 name on the VIT website, including, without limitation, YOUR display of PLAYBOY’s name as an
10 affiliate partner in the adult entertainment group.
12 All DOCUMENTS and COMMUNICATIONS relating to YOUR representation and warranty
13 that YOU had “sufficient and available funds” to make the $4,000,000 cash payment to PLAYBOY.
15 DOCUMENTS sufficient to show the amount and nature of YOUR funds at the time YOU
16 entered into the MOU.
18 All DOCUMENTS and COMMUNICATIONS relating to YOUR relationship with VIT.
20 All DOCUMENTS and COMMUNICATIONS relating to YOUR financial interest, if any, in
21 VIT or the VICE TOKEN.
23 All DOCUMENTS and COMMUNICATIONS relating to Shidan Gouran’s relationship with
24 VIT.
26 All DOCUMENTS and COMMUNICATIONS relating to Shidan Gouran’s financial interest, if
27 any, in VIT or the VICE TOKEN.
28
9
2 All DOCUMENTS and COMMUNICATIONS relating to the CROWDSALE.
4 All DOCUMENTS and COMMUNICATIONS relating to the cash proceeds generated from the
5 CROWDSALE.
7 All DOCUMENTS and COMMUNICATIONS relating to what YOU did with the cash
8 proceeds generated from the CROWDSALE.
10 DOCUMENTS sufficient to provide an accounting relating to the cash proceeds from the
11 CROWDSALE.
13 All DOCUMENTS and COMMUNICATIONS relating to YOUR promise to provide stock to
14 PLAYBOY in the event the CROWDSALE raised less than $4,000,000.
16 All DOCUMENTS and COMMUNICATIONS relating to Shidan Gouran’s authority to
17 promise, on YOUR behalf, that YOU would provide stock to PLAYBOY in the event the
18 CROWDSALE raised less than $4,000,000.
20 All DOCUMENTS and COMMUNICATIONS relating to YOUR board of directors’
21 ratification, endorsement, or approval, if any, of YOUR promise to provide stock to PLAYBOY in the
22 event the CROWDSALE raised less than $4,000,000.
24 All DOCUMENTS and COMMUNICATIONS relating to YOUR decision not to disclose to
25 investors in YOUR July 2, 2018 press release that the PLAYBOY project was not on schedule and/or
26 that significant delays and roadblocks existed with respect to the PLAYBOY project.
27
28
10
2 All DOCUMENTS and COMMUNICATIONS relating to the email from Reena Patel to Shidan
3 Gouran dated July 6, 2018, a copy of which is attached to the REQUESTS FOR ADMISSION as
4 Exhibit 2.
6 All DOCUMENTS and COMMUNICATIONS relating to the letter from Reena Patel to Shidan
8 Exhibit 3.
10 All DOCUMENTS and COMMUNICATIONS relating to the email from Reena Patel to Shidan
12 Exhibit 4.
14 All DOCUMENTS and COMMUNICATIONS relating to the letter from Susan Leader to Barry
15 Rotenberg dated July 13, 2018, a copy of which is attached to the REQUESTS FOR ADMISSION as
16 Exhibit 5.
18 All DOCUMENTS and COMMUNICATIONS relating to Shidan Gouran’s statement to the LA
19 Times that this ACTION is a “normal dispute.”
21 All DOCUMENTS and COMMUNICATIONS relating to Shidan Gouran’s statement to the LA
22 Times that PLAYBOY’s allegation of fraud is “frivolous.”
24 Copies of all insurance policies covering or insuring Shidan Gouran, including but not limited
25 to D&O policies, professional liability policies, management liability policies, and errors and
26 omissions policies.
27
28
11
1 RAINES FELDMAN LLP
Laith D. Mosely (Bar No. 250832)
2 lmosely@raineslaw.com
Lawrence J.H. Liu (Bar No. 312115)
3 lliu@raineslaw.com
18401 Von Karman Ave., Suite 360
4 Irvine, California 92612
Telephone: (310) 440-4100
5 Facsimile: (310) 449-4877
6 Attorneys for Defendant, Global Blockchain Technologies Corporation, a Canadian

corporation
7

9 COUNTY OF LOS ANGELES CENTRAL DISTRICT
10
11 PLAYBOY ENTERPRISES, INC., a Case No. BC716374

Delaware Corporation,
12 Assigned to for All Purposes to:
13 Plaintiff, Hon. Susan Bryant-Deason, Dept. 52
14 vs.
15 DEFENDANT GLOBAL
GLOBAL BLOCKCHAIN BLOCKCHAIN TECHNOLOGIES
16 TECHNOLOGIES CORPORATION, a RESPONSES TO
Canadian corporation; and DOES 1-10, PLAINTIFF PLAYBOY
17 REQUESTS
FOR PRODUCTION OF DOCUMENTS
18 Defendants. AND THINGS, SET ONE
19
20
21 Complaint filed: August 3, 2018

24 SET NO.: ONE
25
26 Pursuant to California Code of Civil Procedure sections 2030.010 et seq., Defendant

27 ponding
28
-1-
DEFENDANT GBT RESPONSES REQUESTS FOR
PRODUCTION OF DOCUMENTS AND THINGS, SET ONE
1 First Set of Requests for Production of
2 Documents and Things on Defendant GBT as follows:
3 PRELIMINARY STATEMENT
4 In responding to the document requests, Responding Party will endeavor to produce
5 those responsive documents presently known by or available to Responding Party which
7 discovery, investigation, and preparation for trial have not been completed as of the date of
8 these responses. Responding Party anticipates that ongoing discovery and investigation
9 may uncover documents not presently known but upon which it necessarily will rely in this
10 action. Consequently, the responses contained herein are not intended to and shall not
11 preclude Responding Party from relying upon documents uncovered during ongoing
12 discovery and investigation related to this action, whether or not identified or produced
13 herein. As discovery is ongoing and continuing with respect to each of the categories of
14 documents sought by the document requests, Responding Party reserves the right to
15 supplement and/or amend these responses to the document requests at any time up to and
16 including the trial of this action.
17 GENERAL OBJECTIONS
18 1. Responding Party objects to each of the Requests to the extent that it calls for
19 the production of documents protected by the attorney-client privilege, the attorney work-
20 product doctrine, the joint defense privilege, the common interest privilege, and/or any
21 other applicable privilege. Any inadvertent production of such information shall not be
22 deemed to waive any privilege with respect to such information or any work product
23 doctrine which may attach thereto.
24 2. Responding Party objects to each of the Requests to the extent that it seeks
25 documents in the possession or control of individuals or entities other than Responding
26 Party.
27
28
-2-
1 3. Responding Party objects to each of the Requests to the extent it calls for
2 production of documents that are neither relevant to the subject matter involved in the
3 pending action nor reasonably calculated to lead to the discovery of admissible evidence.
4 4. Responding Party objects to each of the Requests to the extent that it calls for
5 Responding Party to create compilations of material or calls for matters to be produced in a
6 form or manner other than that kept by Responding Party, and/or its employees, affiliated
7 companies, and/or parent companies, in the usual course of business.
8 5. Responding Party objects to the production and inspection of documents at

9 the offices of
10 acceptable date to be delivered electronically to Plainti
11 6. Responding Party may be unable to locate all requested documents by the

12 date specified for production. Should Responding Party in the future locate any relevant
13 requested documents now in existence but not yet located, Responding Party will so advise
14 counsel for Plaintiff and make such documents available to Plaintiff, subject to the
15 objections and comments set forth in these responses.
16 7. Responding Party objects to the instructions to the extent that they conflict
17 with the provisions of California Code of Civil Procedure Section 2031.010, et seq., or
18 seek to impose additional obligations upon GBT beyond those set forth under California
19 Code of Civil Procedure section 2031.010. GBT will respond in accordance with the
20 requirements of California Code of Civil Procedure sections 2031.010 et seq.
21 Each and every general objection above is incorporated into each response below.
22 REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
24 All DOCUMENTS and COMMUNICATIONS relating to PLAYBOY.

25 RESPONSE TO REQUEST FOR ADMISSION NO. 1:
27 overbroad, cumulative, unduly burdensome, oppressive, harassing, and not reasonably
28 calculated to lead to the discovery of admissible evidence. (Code Civ. Proc., §§ 2017.010;
-3-
1 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects to the
2 extent that the request corporate right of privacy. (SCC

3 Acquisitions, Inc. v. Superior Court (2015) 243 Cal.App.4th 741, 756.) Responding Party
4 further objects to the extent that the request intrudes on the constitutionally-protected
5 individual right of privacy. (Cal. Const., art. I, § 1.) Responding Party also objects to the
6 extent that the request calls for information protected under attorney-client privilege and/or
8 Subject to, and without waiving the aforementioned objections, Responding Party
9 responds that it will produce the non-privileged documents in its possession, custody, or
10 control that are responsive to this request.
12 All COMMUNICATIONS between YOU and PLAYBOY.

13 RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
16 calculated to lead to the discovery of admissible evidence. Moreover, the request seeks
17 documents already in the possession of Propounding Party. (Code Civ. Proc., §§ 2017.010;
18 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).)
23 All COMMUNICATIONS between Shidan Gouran and PLAYBOY.

27 calculated to lead to the discovery of admissible evidence Mr. Gouran is not a party to
28 this action. Moreover, the request seeks documents already in the possession of
-4-
1 Propounding Party. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a);
2 2031.060, subd. (b).)
7 All COMMUNICATIONS between Shidan Gouran and any other person or entity
8 regarding PLAYBOY.
13 this action. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a); 2031.060, subd.
14 (b).) Responding Party objects to the extent that the request intrudes on Responding
15 SCC Acquisitions, Inc. v. Superior Court, supra, 243

16 Cal.App.4th at 756.) Responding Party further objects to the extent that the request
17 intrudes on the constitutionally-protected individual right of privacy. (Cal. Const., art. I, §
18 1.) Responding Party also objects to the extent that the request calls for information
20 Proc., §§ 2018.010 et seq.)
25 All DOCUMENTS and COMMUNICATIONS relating to the MOU.

-5-
2 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party also objects to the
9 All drafts of the MOU.

14 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects on the basis
15
16 unintelligible. Responding Party also objects to the extent that the request calls for
17 information protected under attorney-client privilege and/or the work product doctrine.
18 (Code Civ. Proc., §§ 2018.010 et seq.)
23 All COMMUNICATIONS between Shidan Gouran and any other person or entity
24 relating to the MOU.
-6-
3 (SCC Acquisitions, Inc. v. Superior Court, supra, 243

8 Proc., §§ 2018.010 et seq.)
13 All DOCUMENTS and COMMUNICATIONS relating to VIT.

25 s dealings,
26 discussions, or interactions with PLAYBOY.
-7-
4 and ambiguous to the

5 extent the request is unintelligible. Responding Party also objects to the extent that the
6 request calls for information protected under attorney-client privilege and/or the work
7 product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
12 All DOC
13 with the MOU.
19 that the phrase involvement in or with so vague and ambiguous to the extent the
20 request is unintelligible. Responding Party also objects to the extent that the request calls
21 for information protected under attorney-client privilege and/or the work product doctrine.
27 All COMMUNICATIONS between YOU and VIT regarding the MOU.

28
-8-
6 that the phrase regarding the MOU so vague and ambiguous to the extent the request
7 is unintelligible. Responding Party also objects to the extent that the request calls for
14 All COMMUNICATIONS between YOU and VIT regarding PLAYBOY.

20 that the phrase regarding PLAYBOY so vague and ambiguous to the extent the
28 All COMMUNICATIONS between YOU and VIT regarding the ACTION.
-9-
6 that the phrase regarding the ACTION so vague and ambiguous to the extent the
14 All COMMUNICATIONS between Shidan Gouran and VIT regarding the MOU.
21 y. (SCC Acquisitions, Inc. v. Superior Court, supra, 243

24 1.) Responding Party objects on the basis that the phrase regarding the MOU so vague
25 and ambiguous to the extent the request is unintelligible. Responding Party also objects to
26 the extent that the request calls for information protected under attorney-client privilege
27 and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
-10-
4 All COMMUNICATIONS between Shidan Gouran and VIT regarding PLAYBOY.

11 (SCC Acquisitions, Inc. v. Superior Court, supra, 243

14 1.) Responding Party objects on the basis that the phrase regarding PLAYBOY so
15 vague and ambiguous to the extent the request is unintelligible. Responding Party also
16 objects to the extent that the request calls for information protected under attorney-client
17 privilege and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
22 All COMMUNICATIONS between Shidan Gouran and VIT regarding the

23 ACTION.
-11-
2 acy. (SCC Acquisitions, Inc. v. Superior Court, supra, 243

5 1.) Responding Party objects on the basis that the phrase regarding the ACTION so
6 vague and ambiguous to the extent the request is unintelligible. Responding Party also
13 All COMMUNICATIONS between YOU and Stephen Michael Kernan, or any

14 other principal, agent, or representative of The Kernan Law Firm, including, but not
15 limited to, any retainer agreements or invoices.
19 calculated to lead to the discovery of admissible evidence neither Stephen Michael

20 Kernan nor the Kernan Law Firm are parties to this action. (Code Civ. Proc., §§ 2017.010;
21 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects to the
22 extent that the request intrudes (SCC

23 Acquisitions, Inc. v. Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party
24 further objects to the extent that the request intrudes on the constitutionally-protected
25 individual right of privacy. (Cal. Const., art. I, § 1.)Responding Party also objects to the
-12-
1 responds: After a diligent search and reasonable inquiry, Responding Party is unable to
2 locate any documents responsive to this request. Discovery is pending, and Responding
3 Party reserves the right to amend this response later.
5 All COMMUNICATIONS between Shidan Gouran and Stephen Michael Kernan,

6 or any other principal, agent, or representative of The Kernan Law Firm, including, but not
7 limited to, any retainer agreements or invoices.
11 calculated to lead to the discovery of admissible evidence neither Mr. Gouran nor
12 Stephen Michael Kernan and the Kernan Law Firm are parties to this action. (Code Civ.
13 Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party
14 objects to the extent that the
15 privacy. (SCC Acquisitions, Inc. v. Superior Court, supra, 243 Cal.App.4th at 756.)
16 Responding Party further objects to the extent that the request intrudes on the
17 constitutionally-protected individual right of privacy. (Cal. Const., art. I, § 1.) Responding
18 Party also objects to the extent that the request calls for information protected under
19 attorney-client privilege and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010
20 et seq.)

26 All DOCUMENTS and COMMUNICATIONS relating to the VICE TOKEN.

-13-
3 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party further objects on
5 that the term is unintelligible. Responding Party also objects to the extent that the request
12 All DOCUMENTS and COMMUNICATIONS relating to the $4,000,000 cash

13 payment that YOU promised to make to PLAYBOY.
15 This request incorrectly assumes that the MOU is a binding agreement or promise.
16 Responding Party objects on the basis that the interrogatory is vague as to time, overbroad,
17 cumulative, unduly burdensome, oppressive, harassing, and not reasonably calculated to
18 lead to the discovery of admissible evidence. (Code Civ. Proc., §§ 2017.010; 2017.020,
19 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects on the basis that the
20 term are so vague and ambiguous to the

21 extent that the request is unintelligible. Responding Party also objects to the extent that the
28 All DOCUMENTS and COMMUNICATIONS relating to YOUR failure to make
-14-
1 the $4,000,000 cash payment that YOU promised to make to PLAYBOY.
8 , are so vague and

9 ambiguous to the extent that the request is unintelligible. Responding Party also objects to

17 All DOCUMENTS and COMMUNICATIONS relating to YOUR promise to

18 provide technical support to PLAYBOY.
25
-15-
5 All DOCUMENTS and COMMUNICATIONS relating to the technical support, if

6 any, that YOU provided to PLAYBOY.
12
20
26
-16-

7 remove references
14
15 vague and ambiguous to the extent that the request is unintelligible. Responding Party also
22 All DOCUMENTS and COMMUNICATIONS relating to YOUR removal, if any,

23 of references
-17-
1 that the te removal

10 website.
17
18 that the request is unintelligible. Responding Party also objects to the extent that the
25 All DOCUMENTS and COMMUNICATIONS relating to YOUR rebranding, if

26 any, of the VIT website.
-18-
12 All DOCUMENTS and COMMUNICATIONS relating to YOUR removal, if any,

13 of the words
19
20 the request is unintelligible. Responding Party also objects to the extent that the request
27 All DOCUMENTS and COMMUNICATIONS relating to YOUR subsequent

28 reintroduction of
-19-
2 This request incorrectly assumes that Responding Party reintroduced the words
3 Responding Party objects on the basis that
4 the interrogatory is vague as to time, overbroad, cumulative, unduly burdensome,
5 oppressive, harassing, and not reasonably calculated to lead to the discovery of admissible
6 evidence. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a); 2031.060, subd.
7 (b).)
8 request is unintelligible.
9 Responding Party also objects to the extent that the request calls for information protected
11 2018.010 et seq.)

17 All DOCUMENTS and COMMUNICATIONS relating to any changes made to the

18 VIT website after YOU entered into the MOU.
20 This request incorrectly assumes that Responding Party made changes to the VIT
21 website after it had entered into the MOU. Responding Party objects on the basis that the
22 interrogatory is vague as to time, overbroad, cumulative, unduly burdensome, oppressive,
23 harassing, and not reasonably calculated to lead to the discovery of admissible evidence.
24 (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).)
25
-20-
5 All DOCUMENTS and COMMUNICATIONS relating to YOUR reference to the

6 service as
12 the
13
14 Responding Party also objects to the extent that the request calls for information protected
16 2018.010 et seq.)
21 All DOCUMENTS and COMMUNICATIONS relating to YOUR display of

22 name on the VIT website, including, without limitation, YOUR display of
23 affiliate partner in the adult entertainment group.
25
26
27 partner in the adult entertainment group. Responding Party objects on the basis that the
28 interrogatory is vague as to time, overbroad, cumulative, unduly burdensome, oppressive,
-21-
1 harassing, and not reasonably calculated to lead to the discovery of admissible evidence.
2 (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a); 2031.060, subd. (b).)
5 to the extent that the request is unintelligible. Responding Party also objects to the extent
6 that the request calls for information protected under attorney-client privilege and/or the
12 All DOCUMENTS and COMMUNICATIONS relating to YOUR representation

13 and warranty
14 payment to PLAYBOY.
20 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects on the basis that no
21
22 (Civ. Code, § 3295; Kerr v. Rose (1990) 216 Cal.App.3d 1551, 1565; Jabro v. Superior
23 Court (2002) 95 Cal.App.4th 754, 758.) Responding Party objects to the extent that the
24 SCC Acquisitions, Inc.

25 v. Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party objects on the basis
26
-22-
6 DOCUMENTS sufficient to show the amount and nature of YOUR funds at the
7 time YOU entered into the MOU.
13
14 order. (Civ. Code, § 3295; Kerr v. Rose, supra, 216 Cal.App.3d at 1565; Jabro v. Superior
15 Court, supra, 95 Cal.App.4th at 758.) Responding Party objects to the extent that the

18 that the phrase are so vague and

26 All DOCUMENTS and COMMUNICATIONS relating to YOUR relationship with

27 VIT.
28
-23-
14 All DOCUMENTS and COMMUNICATIONS relating to YOUR financial interest,

15 if any, in VIT or the VICE TOKEN.
21

26
27 is unintelligible. Responding Party also objects to the extent that the request calls for
-24-
2 Based on the foregoing objections, Responding Party is unable to comply with this
3 request but invites Propounding Party to meet and confer regarding the information
4 requested.
7 relationship with VIT.
13
21
22 financial interest, if any, in VIT or the VICE TOKEN.
-25-
2 Cal.App.4th at 756.) Responding Party objects on the basis that no pretrial discovery as to
3 Kerr
4 v. Rose, supra, 216 Cal.App.3d at 1565; Jabro v. Superior Court, supra, 95 Cal.App.4th at
5 758.) Responding Party objects based on the constitutional right to privacy to the extent
7 art 1, § 1; City of Carmel-by-the-Sea v. Young (1970) 2 Cal.3d 258, 266-268 [protection of
8 against public disclosure is an aspect of the zone of

9 privacy which is protected by the Fourth Amendment and which also falls within the that
10 penumbra of constitutional rights into which the government may not intrude absent a
11 ; see also Fortunado v. Superior Court (2003) 114

12 Cal.App.4th 475, 480-482.) Responding Party objects on the basis that the phrase
13
19 requested.
21 All DOCUMENTS and COMMUNICATIONS relating to the CROWDSALE.

27
28 the request is unintelligible. Responding Party objects on the basis that no pretrial
-26-
1 discovery as to Respondin
2 Code, § 3295; Kerr v. Rose, supra, 216 Cal.App.3d at 1565; Jabro v. Superior Court,
3 supra, 95 Cal.App.4th at 758.) Responding Party objects to the extent that the request
4 intrudes on Responding SCC Acquisitions, Inc. v.

5 Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party also objects to the
12 All DOCUMENTS and COMMUNICATIONS relating to the cash proceeds

13 generated from the CROWDSALE.
19
20 extent the request is unintelligible. Responding Party objects on the basis that no pretrial
21 without a court order. (Civ.

24 y. (SCC Acquisitions, Inc. v.

25 Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party also objects to the
-27-
2 requested.
4 All DOCUMENTS and COMMUNICATIONS relating to what YOU did with the
5 cash proceeds generated from the CROWDSALE.
11
12 extent the request is unintelligible. Responding Party objects on the basis that no pretrial
13
16 SCC Acquisitions, Inc. v.

17 Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party objects on the basis that
18 the request calls for a legal conclusion. Responding Party also objects to the extent that the
23 requested.
25 DOCUMENTS sufficient to provide an accounting relating to the cash proceeds

26 from the CROWDSALE.
-28-
5 ambiguous to the extent the request is unintelligible. Responding Party objects on the basis

11 that the request calls for a legal conclusion. Responding Party also objects to the extent
12 that the request calls for information protected under attorney-client privilege and/or the
16 requested.

19 provide stock to PLAYBOY in the event the CROWDSALE raised less than $4,000,000.
26
-29-
7 authority to promise, on YOUR behalf, that YOU would provide stock to PLAYBOY in
8 the event the CROWDSALE raised less than $4,000,000.
15
16 the request is unintelligible. Responding Party also objects to the extent that the request
23 All DOCUMENTS and COMMUNICATIONS relating to YOUR board of

24 of YOUR promise to provide stock
25 to PLAYBOY in the event the CROWDSALE raised less than $4,000,000.
-30-
3 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects to the extent that the

6 that t
14 All DOCUMENTS and COMMUNICATIONS relating to YOUR decision not to

15 disclose to investors in YOUR July 2, 2018 press release that the PLAYBOY project was
16 not on schedule and/or that significant delays and roadblocks existed with respect to the
17 PLAYBOY project.
23 not on schedule significant delays roadblocks

24 ambiguous to the extent that the request is unintelligible. Responding Party objects to the
25 SCC
26 Acquisitions, Inc. v. Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party
27 also objects to the extent that the request calls for information protected under attorney-
28 client privilege and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
-31-
6 All DOCUMENTS and COMMUNICATIONS relating to the email from Reena

7 Patel to Shidan Gouran dated July 6, 2018, a copy of which is attached to the REQUESTS
8 FOR ADMISSION as Exhibit 2.
12 calculated to lead to the discovery of admissible evidence the request seeks documents
13
14 Gouran are parties in this action. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030,
15 subd. (a); 2031.060, subd. (b).) Responding Party also objects to the extent that the request
22 All DOCUMENTS and COMMUNICATIONS relating to the letter from Reena

-32-
1
10 All DOCUMENTS and COMMUNICATIONS relating to the email from Reena

17 already within Propou
26 All DOCUMENTS and COMMUNICATIONS relating to the letter from Susan

27 Leader to Barry Rotenberg dated July 13, 2018, a copy of which is attached to the
28 REQUESTS FOR ADMISSION as Exhibit 5.
-33-
12
13 statement to the LA
15 This request incorrectly assumes that Mr. Gouran made a statement to the LA
16 Times regarding this action. Responding Party objects on the basis that the interrogatory is
17 vague as to time, overbroad, cumulative, unduly burdensome, oppressive, harassing, and
18 not reasonably calculated to lead to the discovery of admissible evidence Mr. Gouran is
19 not a party to this action. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a);
20 2031.060, subd. (b).) Responding Party further objects to the extent that the request
24 Proc., §§ 2018.010 et seq.)

-34-
3 statement to the LA
5 This request incorrectly assumes that Mr. Gouran made a statement to the LA
6 Times regarding this action. Responding Party objects on the basis that the interrogatory is
7 vague as to time, overbroad, cumulative, unduly burdensome, oppressive, harassing, and
8 not reasonably calculated to lead to the discovery of admissible evidence Mr. Gouran is
9 not a party to this action. (Code Civ. Proc., §§ 2017.010; 2017.020, 2019.030, subd. (a);
10 2031.060, subd. (b).) Responding Party further objects to the extent that the request
14 Proc., §§ 2018.010 et seq.)

20 Copies of all insurance policies covering or insuring Shidan Gouran, including but
21 not limited to D&O policies, professional liability policies, management liability policies,
22 and errors and omissions policies.
-35-
2 Cal.App.4th at 756.) Responding Party further objects based on the constitutional right to
4 finances. (Cal. Const. art 1, § 1; City of Carmel-by-the-Sea v. Young, supra, 2 Cal.3d at
5 266- affairs . . . against public disclosure is an

6 aspect of the zone of privacy which is protected by the Fourth Amendment and which also
7 falls within the that penumbra of constitutional rights into which the government may not
8 intrude absent a showing of comp Fortunado v. Superior Court

9 (2003) 114 Cal.App.4th 475, 480-482.) Responding Party also objects to the extent that the
16 All COMMUNICATIONS between YOU and any other person, including but not
17 limited to any insurance provider, regarding potential insurance coverage of this ACTION.
28
-36-
2 All DOCUMENTS and COMMUNICATIONS identified in response to

3 PLAYBOY s INTERROGATORIES.
5 Responding Party objects on the basis that the interrogatory is vague, overbroad,
8 2019.030, subd. (a); 2031.060, subd. (b).) Responding Party objects to the extent that the

10 v. Superior Court, supra, 243 Cal.App.4th at 756.) Responding Party further objects to the
11 extent that the request intrudes on the constitutionally-protected individual right of privacy.
12 (Cal. Const., art. I, § 1.) Responding Party also objects to the extent that the request calls
18
19 Dated: November 7, 2018 RAINES FELDMAN LLP

20
21
By:
22 Laith D. Mosely
Lawrence J.H. Liu
23 Attorneys for Defendant, Global
Blockchain Technologies Corporation, a
24
Canadian corporation
25
26
27
28
-37-
ANDREW S. JICK (SBN 278943)
3 ajick@akingump.com
Telephone: 310.229.1000
5 Facsimile: 310.229.1001
6 Attorneys for Plaintiff
7

11
PLAYBOY ENTERPRISES, INC., a Case No. BC716374
12 Delaware Corporation,
13 Plaintiff,
PLAINTIFF PLAYBOY ENTERPRISES, INC.’S
14 v. SPECIAL INTERROGATORIES TO
DEFENDANT GLOBAL BLOCKCHAIN
15 GLOBAL BLOCKCHAIN TECHNOLOGIES CORPORATION, SET ONE
TECHNOLOGIES CORPORATION, a
16 Canadian Corporation; and DOES 1-10,
inclusive,
17
Defendants.
18 Date Action Filed: August 3, 2018
19

22 SET NO: One
23
24
25
26
27
28
PLAINTIFF PLAYBOY ENTERPRISES, INC.’S SPECIAL INTERROGATORIES TO DEFENDANT GLOBAL

BLOCKCHAIN TECHNOLOGIES CORPORATION, SET ONE
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 Pursuant to California Code of Civil Procedure § 2030.010 et seq., Plaintiff Playboy
3 Enterprises, Inc. (“PLAYBOY”) hereby propounds this First Set of Special Interrogatories
4 (“Interrogatories”) on Defendant Global Blockchain Technologies Corporation (“YOU” or “YOUR”).
5 Pursuant to California Code of Civil Procedure §§ 2030.210 and 2030.260, the verified responses to
6 these Interrogatories are due within 30 days of service, to the offices of Akin Gump Strauss Hauer &
7 Feld LLP, 1999 Avenue of the Stars, Suite 600, Los Angeles, California 90067.
8 In answering these Interrogatories, Defendant must provide not only information actually
9 possessed by it, but also all information reasonably available to Defendant, its attorneys, and anyone
10 working on its behalf.
11 SPECIAL INTERROGATORIES
13 Describe, with particularity, any dealings, discussions, or interactions between VIT and
14 PLAYBOY relating to the MOU, including, without limitation, identifying all PERSONS with
16 (As used herein, the term “VIT” refers to Vice Industry Token, Inc., its parents, subsidiaries,
17 affiliates, attorneys, paralegals, agents, accountants, consultants, representatives, directors, officers,
18 employees, experts, independent contractors, and any other person or entity associated with any of the
19 above individuals or entities, and any other person acting or purporting to act on its behalf.)
20 (As used herein, the term “PLAYBOY” shall refer to Playboy Enterprises, Inc., its parents,
21 subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants, representatives,
22 directors, officers, employees, experts, independent contractors, and any other person or entity
23 associated with any of the above individuals or entities, and any other person acting or purporting to
24 act on its behalf.)
25 (As used herein, the term “MOU” refers to the Memorandum of Understanding between
26 PLAYBOY and YOU dated March 13, 2018.)
27 (As used herein, the words “YOU” and “YOUR” shall refer to Defendant Global Blockchain
28 Technologies Corporation, its parents, subsidiaries, affiliates, attorneys, paralegals, agents,
1
1 accountants, consultants, representatives, directors, officers, employees, experts, independent
2 contractors, and any other person or entity associated with any of the above individuals or entities, and
3 any other person acting or purporting to act on its behalf.)
4 (As used herein, the term “PERSONS” means all natural persons. It does not refer to
5 corporations, partnerships, trusts, entities, or other associations.)
7 Describe, with particularity, the reason(s) why YOU did not make the payment to PLAYBOY
8 of $4,000,000, in cash or stock, by July 16, 2018, including, without limitation, identifying all
9 PERSONS with knowledge regarding this topic.
11 Describe, with particularity, the technical support that YOU provided to PLAYBOY, including,
12 without limitation, identifying all PERSONS with knowledge regarding this topic.
14 Describe, with particularity, all changes YOU made to the VIT website relating to PLAYBOY
15 or the MOU, including, without limitation, identifying all PERSONS with knowledge regarding this
16 topic.
18 Describe, with particularity, the amount and nature of YOUR funds at the time YOU entered
19 into the MOU, including, without limitation, identifying all PERSONS with knowledge regarding this
20 topic.
22 Describe, with particularity, the cash proceeds that YOU received from the CROWDSALE,
23 including, without limitation, identifying all PERSONS with knowledge regarding this topic.
24 (As used herein, the term “CROWDSALE” shall refer to the crowdsale referenced in the MOU
25 which was held from February 20, 2018 to March 20, 2018.)
26
27
28
2

Playboy vs. Shidan Gouran - August 1 Supplemental 122

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Playboy vs. Shidan Gouran - August 1 Supplemental 122

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Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 06:52 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by R. Sanchez,Deputy Clerk

1 AKIN GUMP STRAUSS HAUER & FELD LLP

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

7. EMAIL ADDRESS FOR RECEIVING STATUTORY NOTIFICATIONS

12. NAME ADDRESS CITY STATE ZIP CODE

13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: 0

16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION

6 Attorneys for Defendant, Global Blockchain Technologies Corporation, a Canadian

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

11 PLAYBOY ENTERPRISES, INC., a Case No. BC716374

14 discovered facts, documents, and witnesses.

20 interrogatory is not intended and shall not be construed to be a waiver by Responding

3 case, nor reasonably calculated to lead to the discovery of admissible evidence.

4 3. Responding Party objects to the Interrogatories to the extent they seek

7 4. Responding Party objects to the Interrogatories to the extent they seek

13 5. Responding Party objects to the Interrogatories to the extent they seek

15 work- product doctrine, or any other applicable privilege or protection. Responding

17 waiving, any applicable objection, privilege, or protection. Inadvertent disclosure of

18 information subject to a claim of privilege or protection is not, and may not be

19 deemed, a waiver of that privilege or protection. Unless otherwise stated, Responding

25 6. To the extent that any Interrogatory or response implicates Responding

27 right to designate such information as needed under a protective order.

3 right to search and, if appropriate, produce responsive, non-privileged information from

6 8. Responding Party's election to respond to an Interrogatory, notwithstanding

8 with, any of the characterizations or purported descriptions of the transactions or

15 defined term is at issue in this action.

16 9. Responding Party reserves the right to amend, supplement, or alter these

19 Responding Party's right to rely on other facts or documents.

23 Describe, with particularity, any dealings, discussions, or interactions between VIT

25 PERSONS with knowledge regarding this topic.

28 representatives, directors, officers, employees, experts, independent contractors, and any

2 other person acting or purporting to act on its behalf.)

4 parents, subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants,

5 representatives, directors, officers, employees, experts, independent contractors, and any

7 other person acting or purporting to act on its behalf.)

9 between PLAYBOY and YOU dated March 13, 2018.)

11 Blockchain Technologies Corporation, its parents, subsidiaries, affiliates, attorneys,

12 paralegals, agents, accountants, consultants, representatives, directors, officers, employees,

17 to corporations, partnerships, trusts, entities, or other associations.)

18 RESPONSE TO SPECIAL INTERROGATORY NO. 1:

23 discovery of admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party

27 cords and files. (Code Civ. Proc., § 2019.030,

4 Subject to and without waiving the aforementioned objections, Responding Party

8 payments through Playboy.t . In discussions with GBT, Playboy

10 technical aspects of the integration.

11 Playboy, however, failed to

17 SPECIAL INTERROGATORY NO. 2:

20 limitation, identifying all PERSONS with knowledge regarding this topic.

21 RESPONSE TO SPECIAL INTERROGATORY NO. 2:

22 This interrogatory incorrectly assumes that the MOU is a binding agreement or

2 the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

3 Subject to and without waiving the aforementioned objections, Responding Party

8 In addition, Playboy did not attempt to

19 however, has rebuffed such requests for further discussions.

20 SPECIAL INTERROGATORY NO. 3:

21 Describe, with particularity, the technical support that YOU provided to

23 regarding this topic.

24 RESPONSE TO SPECIAL INTERROGATORY NO. 3:

2 objects on the basis that the terms undefined and

9 work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

10 Subject to and without waiving the aforementioned objections, Responding Party

13 Individuals with knowledge include: Shidan Gouran; David