These are true and correct excerpts from sworn certifications filed on June 30 and July 3, 2014.
The certifications were filed as exhibits in support of Plaintiffs' opposition to my Motion to Compel Plaintiffs To Produce Discovery Ordered on April 25, 2014 or Dismiss or Strike Complaint.
PLAINTIFF LANE BAJARDI
|Plaintiffs' EXHIBIT E-Lane Bajardi certification|
WITNESS PERRY KLAUSSEN
|Plaintiffs' EXHIBIT H-Perry Klaussen certification|
On August 4, 2014, the following were included as exhibits in support of my Motion for Summary Judgment.
At 10:31 AM on November 19, 2010, Perry Klaussen emails Hoboken411 political ghostwriter, Lane "Red Haven" Bajardi "to help out" with a "political year in review piece."
"Red Haven" Bajardi replies 7 minutes later at 10:38 AM.
Who's "the boss"?
|Eenie... meenie... miney... moe|
On March 22, 2011, Perry Klaussen emails his political ghostwriter, Lane "Red Haven" Bajardi.
At 4:47 AM on May 2, 2011, Hoboken411 emailed Lane "Red Haven" Bajardi:
At 3:52 AM on June 28, 2011, Perry Klaussen emails Lane "Red Haven" Bajardi. "Red Haven" replies at 11:47 AM.
Rattle rattle rattle. Red Haven's shaking his tin cup.
At 12:47 PM, Klaussen responds.
Well folks, you get the idea.
Based on these email documents, a reasonable person would believe that Klaussen's ability to compensate Bajardi for his ghostwriting correlated with Hoboken411's revenue stream from ads. For example, ads bought by businesses like City Bistro ,Lua, and political ads from candidates like Beth Mason. A reasonable person might also believe the beneficiaries of a healthy ad revenue stream would be Perry Klaussen and the political ghostwriter he offers "monetary compensation" to, Lane "Red Haven" Bajardi.
Which may explain why Klaussen asks Lane Bajardi for his "thoughts" and "advice" on advertising strategy.