DECLARATION re [4] Memorandum in Opposition, Declaration of Michael Podolsky by Consumer Opinion, LLC (Attachments: # (1) Exhibit 1 - April 8 2014 Post, # (2) Certificate of Service) (Wolman, Jay)
Page 1 DocuSign Envelope ID: 8352F619-3831-4374-AC27-B038B297FD3B
PageID #:
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
----------------------------------------------------------x
LAW OFFICES OF N.M. GEHI, P.C.,
:
:
Plaintiff,
:
:
- against :
:
CONSUMER OPINION, LLC,
:
:
JOHN DOE #1 aka “Review # 481978” an
:
individual whose name is presently unknown,
:
:
JOHN DOE #2 aka “Review # 949333” an
:
individual whose name is presently unknown,
:
:
Defendants.
----------------------------------------------------------x
Case No.: 1:17-cv-05468-RJD-VMS
DECLARATION OF
MICHAEL PODOLSKY
I, Michael Podolsky, declare:
1.
I am over 18 years of age and have never been convicted of a crime involving fraud
or dishonesty. I have first-hand knowledge of the facts set forth herein, and if called as a witness,
could and would testify competently thereto.
2.
I am a Managing Member of Consumer Opinion, LLC, a Nevada limited liability
company and Defendant in this action.
3.
I make this declaration in support of Defendant’s Memorandum of Law in
Opposition to Request for Judicial Intervention Seeking Order to Show Cause for Preliminary
Injunction and Temporary Restraining Order (“Defendant’s Opposition”).
4.
Plaintiff’s Verified Complaint references a review posted to PissedConsumer.com
dated April 14, 2014.
5.
There was no review of Plaintiff dated April 14, 2014 as alleged in the Complaint,
paragraphs 5 & 18. There is a review dated April 8, 2014, which is one of the URLs listed in
Plaintiff’s Exhibit B. It contains the very language quoted by Plaintiff at paragraph 5 of the
Complaint.Page 2 DocuSign Envelope ID: 8352F619-3831-4374-AC27-B038B297FD3B
PageID #:
6.
A true and correct copy of the April 8, 2014 review is attached as Exhibit 1 to this
Declaration.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.
9/19/Executed on: __________________.
Michael Podolsky
PDF Page 1
PlainSite Cover Page
PDF Page 2
DocuSign Envelope ID: 8352F619-3831-4374-AC27-B038B297FD3B
Case 1:17-cv-05468-RJD-VMS Document 5 Filed 09/19/17 Page 1 of 2 PageID #: 95
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
----------------------------------------------------------x
LAW OFFICES OF N.M. GEHI, P.C.,
:
:
Plaintiff,
:
:
- against :
:
CONSUMER OPINION, LLC,
:
:
JOHN DOE #1 aka “Review # 481978” an
:
individual whose name is presently unknown,
:
:
JOHN DOE #2 aka “Review # 949333” an
:
individual whose name is presently unknown,
:
:
Defendants.
----------------------------------------------------------x
Case No.: 1:17-cv-05468-RJD-VMS
DECLARATION OF
MICHAEL PODOLSKY
I, Michael Podolsky, declare:
1.
I am over 18 years of age and have never been convicted of a crime involving fraud
or dishonesty. I have first-hand knowledge of the facts set forth herein, and if called as a witness,
could and would testify competently thereto.
2.
I am a Managing Member of Consumer Opinion, LLC, a Nevada limited liability
company and Defendant in this action.
3.
I make this declaration in support of Defendant’s Memorandum of Law in
Opposition to Request for Judicial Intervention Seeking Order to Show Cause for Preliminary
Injunction and Temporary Restraining Order (“Defendant’s Opposition”).
4.
Plaintiff’s Verified Complaint references a review posted to PissedConsumer.com
dated April 14, 2014.
5.
There was no review of Plaintiff dated April 14, 2014 as alleged in the Complaint,
paragraphs 5 & 18. There is a review dated April 8, 2014, which is one of the URLs listed in
Plaintiff’s Exhibit B. It contains the very language quoted by Plaintiff at paragraph 5 of the
Complaint.
PDF Page 3
DocuSign Envelope ID: 8352F619-3831-4374-AC27-B038B297FD3B
Case 1:17-cv-05468-RJD-VMS Document 5 Filed 09/19/17 Page 2 of 2 PageID #: 96
6.
A true and correct copy of the April 8, 2014 review is attached as Exhibit 1 to this
Declaration.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.
9/19/2017
Executed on: __________________.
Michael Podolsky
2
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