Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA865327
`
`Filing date:
`
`12/17/2017
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`92061245
`
`Defendant
`Ndoema
`
`NDOEMA
`Lvl 29, 999/9 Rama I Road Khwaeng
`Bangkok, Pathumwan, 10330
`THAILAND
`Email: ndoema@gmail.com
`
`Reply in Support of Motion
`
`NDOEMA
`
`ndoema@gmail.com
`
`/Ndoema/
`
`12/17/2017
`
`Reply-Motion-to-Strike.pdf(170827 bytes )
`Ex-1_Declaration.pdf(110407 bytes )
`Ex-A.pdf(153786 bytes )
`Ex-B.pdf(115941 bytes )
`Ex-C.pdf(114503 bytes )
`Ex-D.pdf(125117 bytes )
`Ex-E.pdf(109632 bytes )
`Ex-F.pdf(119623 bytes )
`Ex-G.pdf(67297 bytes )
`Ex-H.pdf(87753 bytes )
`Ex-I.pdf(195986 bytes )
`Ex-J.pdf(315019 bytes )
`
`

`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`THREE DAUGHTERS INTERNATIONAL LLC
`
`Petitioner,
`
`
` v.
`
`
`
`
`
`
`NDOEMA
`
`Registrant .
`
`
`
`
`Cancellation No. 92061245
`Registration No. 3,316,938
`
`REGISTRANT’S REPLY IN SUPPORT OF HER MOTION TO STRIKE
`
`PETITIONER’S OPPOSITION TO MOTION TO QUASH NOTICE OF DEPOSITION
`
`AND CROSS-MOTION TO COMPEL DISCOVERY AND FOR SANCTIONS
`
`
`
`I NDOEMA (“Registrant”), hereby file this Reply in support of my Motion to Strike Petitioner’s
`
`Opposition to Motion to Quash Notice of Deposition and Cross-Motion to Compel Discovery and for
`
`Sanctions.
`
`My Motion to Quash was filed on October 22, 2017. Therefore, the 20-day deadline for the filing
`
`of Petitioner’s Opposition was November 11, 2017. Consequently, and contrary to Petitioner’s patently
`
`false claims, the due date for Petitioner’s Opposition to my Motion to Quash was neither November 14,
`
`2017 (as Petitioner falsely alleges in its November 14 Opposition), nor November 13, 2017 (as Petitioner
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`yet again falsely and shamefully attempts to argue in its December 4 Opposition).
`
`Petitioner does not and cannot justify its 3-day late filing. Indeed Petitioner’s 3-day late
`
`Opposition is unequivocally and inexcusably untimely. Consequently, and pursuant to TBMP § 517,
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`Petitioner’s Opposition must be stricken.
`
`I find it inconceivable that Petitioner’s desperate legal gamesmanship and ongoing contemptible
`
`tactics could sink so low that I should be forced to argue about kindergarten math.
`
`As for Petitioner’s violative Cross-Motions to Compel and for alleged “Sanctions,” Petitioner
`
`failed entirely to legally substantiate any its claims. Instead Petitioner merely rehashes the same pointless
`
`arguments, the same patently false representations, the same baseless slanderous attacks and the same
`
`legally improper demands that the Board should somehow rule in violation of its very own Order of
`
`November 1, 2017, in violation of the TTAB rules and in violation of the Federal Rules of Civil
`
`Procedure.
`
`
`
`1
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`

`

`
`Clearly, Petitioner’s Opposition and Cross Motions must all be stricken, and my Motion to
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`Quash Notice of Deposition must be granted as conceded.
`
`
`
`I.
`
`PRELIMINARY STATEMENT
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`Petitioner failed entirely to justify its inexcusable 3-day late filing.
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`Indeed, my Motion to Quash was filed on October 22, 2017. Therefore, and contrary to
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`Petitioner’s preposterous claims, the 20-day deadline for the filing of Petitioner’s Opposition was
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`November 11, 2017. Even a five year old can figure that out. However, apparently Petitioner shockingly
`
`believes that the Board cannot count to 20.
`
`
`
`I personally wholly trust that the Board is indeed capable of adding up the numbers and
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`ascertaining that (1) Petitioner’s Opposition dated November 14 was filed 3 days past its November 11,
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`2017 deadline (contrary to Petitioner’s astoundingly false claim that 20 days from October 22, 2017 is
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`allegedly November 13); and (2) that my Motion to Strike is fully compliant with TBMP § 517, and
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`therefore must be granted.
`
`
`
`Petitioner’s revolting blame-shifting tactics alleging that the TTAB itself should purportedly be
`
`held accountable for Petitioner’s own inexcusable violation of TBMP § 502.02, Petitioner’s unjustified
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`and unjustifiable 3-day late filing, Petitioner’s ludicrous fabricated story of alleged “ESTTA
`
`malfunction” and Petitioner’s inane purported “six-minute delay” that never was (and never could be),
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`are all utterly appalling and down right insulting to the Board.
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`
`
`Clearly Petitioner’s consistent showing of bad faith is reaching new heights. Regardless
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`Petitioner’s preposterous antics are utterly pointless.
`
`
`
`Indeed Petitioner’s fraught-with-lies Opposition is not only disgraceful but it is entirely moot in
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`that the entirety of Petitioner’s arguments against my Motion to Strike rests solely on the fabricated story
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`of a fictitious “six-minute delay” and the patently false claim that Petitioner’s Opposition was
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`purportedly “due on November 13, 2017,” when it is indisputably not the case. See Opposition of
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`12/04/2017 at II. ¶ 1
`
`
`
`
`
`It goes without saying that Petitioner’s preposterous arguments (including the handful of non-
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`precedential rulings Petitioner hopelessly throws in to somehow lend its fatuous fabrications with some
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`false semblance of legal authority) are therefore not only meritless but also entirely moot.
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`Truly ironic that Petitioner should feel entitled to amp up its contemptible Opposition by unduly
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`lashing out at me with slanderous accusations, patently false allegations of purported discovery evasion
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`attempts, and ludicrous “legal gamesmanship” claims, especially so in light of Petitioner’s indefensible
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`violative conduct, and given the fact that all I have done is simply move to strike Petitioner’s several-
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`days-late brief in full compliance with TBMP § 517 and diligently sought to uphold my legal rights
`
`
`
`2
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`

`

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`against the pervasiveness and egregiousness of Petitioner’s discovery violations in full compliance with
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`TBMP § 404.03(b).
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`In spite of Petitioner’s best effort to distract from the obvious, the simple truth remains that
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`Petitioner’s 3-day late brief is unequivocally and inexcusably untimely. Consequently, and pursuant to
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`TBMP § 517, Petitioner’s Opposition must be stricken.
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`Furthermore, pursuant to Trademark Rule 2.127(d); pursuant to the TTAB Suspension Order of
`
`November 1, 2017; and pursuant to TBMP § 404.03(b); Petitioner’s violative Cross Motions to Compel
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`Testimony Deposition and Production of Documents and Petitioner’s Motion for alleged “Sanctions”
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`must all be stricken as well.
`
`I therefore respectfully request that my Motion to Quash Notice of Deposition be granted as
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`conceded.
`
`
`
`II.
`
`PETITIONER’S 3-DAY LATE FILING IS UNJUSTIFIED AND INEXCUSABLE
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`1.
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`Petitioner’s “six-minute delay” argument is completely and utterly moot
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`The entirety of Petitioner’s arguments against my Motion to Strike rests solely on a fabricated
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`“six minute delay” that never was (and never could be) given the fact that Petitioner’s Opposition brief
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`was due by November 11, 2017, not November 13 as Petitioner falsely argues. Therefore the entirety of
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`Petitioner’s arguments in its Opposition (at III. A to E) is completely and utterly moot.
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`Petitioner does not once attempt to argue that its 3-day late Opposition should not be stricken,
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`simply because Petitioner cannot do so. Instead, Petitioner (in an appalling show of bad faith)
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`manufactures a fictitious purported “six-minute delay” and argues in vain on the basis of a patently
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`false factual representation.
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`Clearly Petitioner’s arguments are entirely moot, therefore the Motion to Strike must be granted.
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`2.
`
`Petitioner failed entirely to justify its 3-day late filing
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`Petitioner does not once attempt to justify its 3-day late filing. Indeed Petitioner’s 3-day
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`late filing remains utterly unexplained and unexplainable.
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`As already stated, Petitioner’s desperate last-ditch effort to (unsuccessfully) attack my wholly
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`compliant Motion to Strike is utterly in vain in that the entirety of Petitioner’s arguments relies
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`exclusively on the blatantly false premise of an alleged November 13 deadline and a purported “six-
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`minute delay,” however both are pure fiction.
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`Indeed Petitioner’s ludicrous “six minute delay” fabrication is entirely pointless and clearly it is
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`but a mere exercise in distraction from the inescapable fact that Petitioner simply cannot justify why
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`Petitioner’s team of five (5) litigation attorneys waited for days past the November 11, 2017 due date
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`before filing Petitioner’s inexcusably late Opposition of November 14.
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`
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`3
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`

`

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`Petitioner’s Opposition of December 4, 2017, is not only utterly pointless but it is an intolerable
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`waste of the TTAB’s time and resources.
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`Clearly, it is indisputable that Petitioner failed entirely to justify its 3-day late filing, therefore the
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`Motion to Strike must be granted.
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`3.
`
`Petitioner acted in bad faith
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`Petitioner has not and cannot attempt to argue that its 3-day late filing is allegedly “excusable”
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`because it is clearly not the case. Furthermore, though Petitioner attempts mightily hard to (falsely) claim
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`otherwise, Petitioner has made an undeniably strong showing of bad faith.
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`I respectfully remind the Board that, unlike me, Kimberly Briner Conrad of Three Daughters
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`International LLC is not appearing pro se in these proceedings. Indeed, in order to file her bogus fraud
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`claims and carry out her inexplicably hateful character assassination attempts against me, Kimberly
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`Briner Conrad has retained the services of no less than half a dozen litigation attorneys at K&L Gates,
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`which apparently is (according to Wikipedia) the 11th largest Law firm in the world. See Exhibit A
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`Kimberly Briner Conrad’s relentless and vicious legal bullying tactics have all been carefully
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`orchestrated by her fleet of aggressive litigation attorneys, which includes Eric Prager, Seth Gold,
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`Margaux Nair, Kate Hummel and Alexis Douglas. Each and every counsel brags about having extensive
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`trademark litigation experience, with Eric Prager and Seth Gold alone claiming what appears to add up to
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`a combined 40 years of experience in TTAB litigation. See Exhibits B, C, D, E, F and G
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`In addition, Seth Gold further states in a sworn declaration before the US District Court for the
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`Central District of California: “As an attorney working on the Three Daughters TTAB matter and this
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`miscellaneous action, I have access to all correspondence and documents in the file. As a matter of
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`practice, the firm routinely files documents that it receives at or near the time we receive them and the
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`attorneys on the matter make records of telephone conferences they have on the matter. In addition, I
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`regularly speak about this matter with my colleagues who also are attorneys -- including Eric Prager,
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`Margaux Nair, and Kate Hummel.” (emphasis added) See Exhibit H at ¶2
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`Clearly, based on Seth Gold’s very own sworn statements, not just one attorney but an entire team
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`of five (5) litigation attorneys reviewed and discussed my October 22 Motion to Quash. Petitioner’s entire
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`team of five (5) litigation attorneys knew of the 20-day deadline to respond. Consequently, Petitioner’s
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`entire team of five (5) litigation attorneys knew that Petitioner’s Opposition was due by November 11,
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`2017. Yet all five (5) litigation attorneys inexplicably chose to wait for days past the November 11
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`deadline and then decided to file an inexcusably late Opposition brief on November 14, falsely claiming
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`that Petitioner’s Motion had purportedly been filed “within 20 days of the date of service of the Motion,
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`which was served on October 22, 2017.” See Opposition of 11/14/2017 at ¶ 1
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`
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`4
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`

`

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`Petitioner’s appalling showing of bad faith is clearly unarguable. Unless of course, Petitioner
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`were to candidly admit that Eric Prager, Seth Gold, Margaux Nair, Kate Hummel and Alexis Douglas are
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`all incapable of counting to 20.
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`If Petitioner’s patently false statements (in its inexcusably late Opposition of November 14) were
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`not indicting enough, Petitioner’s deplorable conduct did not stop there.
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`Indeed Petitioner’s litigation attorneys managed to outdo themselves with the filing of
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`Petitioner’s subsequent Opposition to my Motion to Strike, in which Petitioner then switched from falsely
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`claiming that its Opposition was purportedly due by November 14, to now arguing (an equally false)
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`November 13 due date.
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`If that was not ludicrous enough, Petitioner’s litigation team managed to raise the bad faith ante
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`even further by manufacturing a preposterous blame-shifting story of alleged “ESTTA malfunction” and
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`bogus six-minute delay to boot.
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`I respectfully remind the Board that we are now approaching the three (3) year mark in this case.
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`Over the course of the last several years, Petitioner’s litigation team has filed dozens of motions against
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`me. And most all have been submitted through the ESTTA by Margaux Nair herself, whose Sworn
`
`Declaration is attached to Petitioner’s shameful Opposition. Margaux Nair is clearly not a newbie to this
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`game. She certainly need not purportedly “learn” how to properly submit a motion through the TTAB
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`online filing system. Clearly at this stage in these proceedings, Ms Nair is fully aware of the ESTTA
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`workings and exhibit size requirements. And based on the track record of Margaux Nair’s TTAB filings
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`in this case alone, she is also unequivocally aware of the time difference between Chicago and
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`Alexandria, VA.
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`Clearly Petitioner’s utterly unexplained (and unexplainable) 3-day late filing is unequivocally not
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`attributable to any lack of knowledge of the TTAB procedural rules by Petitioner’s team of five (5)
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`litigation attorneys. Indeed a mere look at the history of this case clearly shows that Petitioner’s legal
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`team has in fact been in the habit of consistently exploiting its knowledge of these very procedural rules
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`to engage in relentless and wrongful legal gamesmanship and discovery abuse.
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`Furthermore, Petitioner’s inexcusable 3-day late filing is not attributable to any alleged “ESTTA
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`malfunction,” neither can it be attributable to a mere “oversight” or “mistake” unintentionally made by an
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`inexperienced pro se litigant. Simply because it is not the case.
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`Indeed Petitioner’s 3-day late Opposition to my Motion to Quash and subsequent preposterous
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`Opposition to my Motion to Strike are a most indefensible abuse of the TTAB procedural rules and an
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`intolerable waste of the Board’s time and resources.
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`In sum, it is irrefutable that Petitioner has been engaging in entirely improper motion games, and
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`has persisted in willingly carrying out its cynical plan of intentionally gaming the system with complete
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`disregard for the Board’s time and resources.
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`
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`5
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`

`

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`Clearly Petitioner has exercised the textbook definition of bad faith.
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`
`
`III.
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`PETITIONER’S VIOLATIVE CROSS-MOTIONS MUST ALL BE STRICKEN
`
`In regards to Petitioner’s Cross-Motions to Compel Discovery and for alleged “Sanctions,” I have
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`already conclusively argued against them in my Motion to Strike.
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`I have effectively shown that Petitioner’s Cross-Motions are not germane to the Motion to Quash
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`and as such they are unequivocally violative of Trademark Rule 2.127(d) and of the TTAB Suspension
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`Order of November 1, 2017. Therefore, they must all be stricken and given no consideration whatsoever.
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`Petitioner falsely alleges that I purportedly have “no legal basis to strike” its violative Motions
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`when it is clearly indisputable that pursuant to Trademark Rule 2.127(d); pursuant to the TTAB
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`Suspension Order of November 1, 2017; and pursuant to TBMP § 404.03(b); Petitioner’s violative Cross
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`Motions to Compel Testimony Deposition and Production of Documents, and Petitioner’s Motion for
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`alleged “Sanctions” must all be stricken.
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`Petitioner’s Opposition fails entirely to legally substantiate any of its claims. Instead Petitioner
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`simply rehashes the same pointless arguments, the same patently false representations, the same baseless
`
`slanderous attacks and the same unequivocally improper demands that the Board should somehow rule in
`
`violation of its own Order, the TTAB rules and the Federal Rules of Civil Procedure.
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`1.
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`Petitioner’s Motion to Compel Deposition Testimony must be stricken
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`As already shown in my Motion to Strike, Petitioner’s Cross-Motion to Compel Deposition
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`Testimony is not germane to the Motion to Quash, therefore it must be given no consideration.
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`Moreover, even assuming hypothetically — contrary to fact — that Petitioner’s Motion to
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`Compel Deposition Testimony was germane to the Motion to Quash, Petitioner’s Motion should still be
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`denied because Petitioner failed entirely to proffer any credible evidence that I allegedly resided in Los
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`Angeles at the time of service of the challenged Notice of Deposition; or that I currently reside in Los
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`Angeles.
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`Absent credible evidence that I was residing and was employed in Los Angeles at the time
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`Petitioner noticed its Deposition, and absent credible evidence that I currently reside and am employed in
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`Los Angeles, Petitioner is not entitled to take deposition in Los Angeles. Consequently Petitioner’s
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`Notice of Deposition indeed violates TBMP § 404.03(b).
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`Since Petitioner is not legally entitled to take deposition in the first place, Petitioner is not legally
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`entitled to bring a Motion to Compel Deposition Testimony. Indeed Petitioner is legally barred from
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`requesting that the Board compel me to travel to the United States for the taking of deposition.
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`The law is clear, pursuant to TBMP § 404.03(b), the Board will not order a foreign resident to
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`come to the United States for the taking of discovery deposition.
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`2.
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`Petitioner’s Motion to Compel Production of Documents must be stricken
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`6
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`

`

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`As already shown in my Motion to Strike, Petitioner’s Cross-Motion to Compel Production of
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`Documents is not germane to the Motion to Quash.
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` At issue here is a simple notice of deposition, not a subpoena duces tecum. Petitioner’s Notice of
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`Deposition is not tied in any way to any document production. Furthermore Petitioner is not entitled to
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`take deposition in the first place, let alone to demand that the Board allegedly compel production of
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`documents “in advance of” a fictional and would be violative deposition.
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`Clearly Petitioner’s Motion to Compel production of documents responsive to Petitioner’s
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`discovery requests dating back to 2015 is entirely irrelevant to the Motion to Quash. And so is
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`Petitioner’s Motion to Compel responses to its second set of discovery requests of October 28, 2017.
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`
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`Moreover, even assuming hypothetically — contrary to fact — that Petitioner’s Motion to
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`Compel Production of Documents was germane to the Motion to Quash, Petitioner’s Motion should still
`
`be denied because contrary to Petitioner’s false allegations I have not in any way failed to produce
`
`documents responsive to Petitioner’s 2015 Requests. Quite the contrary, I have produced to date over one
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`thousand two hundred (1200) responsive documents in two productions dated February 3, 2016 and
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`October 8, 2016. See Exhibits I and J
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`Furthermore, Petitioner itself acknowledges this fact. See Opposition of 11/14/2017, Prager
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`Declaration at ¶ 5
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`Moreover, Petitioner’s violative discovery requests of October 28, 2017, were served after the
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`automatic stay of proceedings effective as of the filing date of my Motion to Quash on October 22, 2017.
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`Petitioner was effectively barred from seeking discovery as of October 22, 2017. Therefore, and contrary
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`to Petitioner’s false claims, I had no obligation to respond to Petitioner’s requests and no responses were
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`due.
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`In sum, Petitioner’s Motion to Compel Production must be stricken and given no consideration.
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`3.
`
` Petitioner’s Motion for Sanctions must be stricken
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`As already shown in my Motion to Strike, Petitioner’s Cross-Motion for alleged “Sanctions” is
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`not germane to the Motion to Quash, therefore it must be given no consideration.
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`Moreover, even assuming hypothetically — contrary to fact — that Petitioner’s Motion was
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`germane to the Motion to Quash, Petitioner’s Motion should still be denied.
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`Contrary to Petitioner’s false allegations, I have in no way purportedly “failed to comply” with
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`the Board Order of May 10, 2017. Indeed, the TTAB Order of May 10, 2017, in fact denied Petitioner’s
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`Motion to Compel Deposition Testimony.
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`Furthermore, and contrary to Petitioner’s patently false claims, there has been no alleged non-
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`compliance on my part.
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`It is an indisputable fact that Petitioner is simply not legally entitled to take deposition in Los
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`Angeles. To this day, Petitioner has failed to proffer any evidence to the contrary.
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`
`
`7
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`

`

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`I have therefore only acted in full compliance with the TTAB rules and the Federal Rules of Civil
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`Procedure by diligently seeking to uphold my legal rights against the pervasiveness and egregiousness
`
`of Petitioner’s discovery violations, and I have done so in complete compliance with TBMP § 404.03(b).
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`Indeed this rule is in place for a reason. And surely nothing in the Board Order of May 10, 2017
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`grants Petitioner the privilege of engaging in wrongful discovery abuse and of noticing me with violative
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`depositions.
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`
`
`IV. CONCLUSION
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`For all the foregoing reasons, I respectfully request that the Trademark Trial and Appeal Board
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`grant my Motion to Strike and grant my Motion to Quash Petitioner’s Notice of Deposition as conceded.
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`
`
`Dated: December 17, 2017
`
`Respectfully submitted,
`
`
`
`
`
`By:________________________
`
`NDOEMA
`
`Lvl 29, 999/9 Rama I Road Khwaeng
`Bangkok, Pathumwan
`Thailand 10330
`ndoema@gmail.com
`
`
`
`8
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`

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`CERTIFICATE OF SERVICE
`
`
`I hereby certify that a copy of the foregoing Registrant’s Reply in Support of her Motion to Strike
`Petitioner’s Opposition and Cross-Motion to Compel Discovery and for Sanctions was emailed on
`December 17, 2017 pursuant to Amended Trademark Rule 2.119 (as reflected in the Miscellaneous
`Changes to Trademark Trial and Appeal Board Rules in effect as of January 14, 2017) to Petitioner at:
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`
`
`
`Eric A. Prager
`
`eric.prager@klgates.com
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`Signature:
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`
`
`Date: December 17, 2017
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`9
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`EXHIBIT 1
`EXHIBIT 1
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`

`

`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`THREE DAUGHTERS INTERNATIONAL LLC
`
`Petitioner,
`
`
` v.
`
`
`
`
`NDOEMA
`
`Registrant.
`
`
`
`
`Cancellation No. 92061245
`Registration No. 3,316,938
`
`DECLARATION OF NDOEMA IN SUPPORT OF HER REPLY IN SUPPORT OF HER
`
`MOTION TO STRIKE PETITIONER’S OPPOSITION TO MOTION TO QUASH NOTICE OF
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`DEPOSITION AND CROSS-MOTION TO COMPEL DISCOVERY AND FOR SANCTIONS
`
`I, NDOEMA, declare as follows:
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`
`
`
`
`
`
`1. I am over the age of 18 years and competent to testify to the matters contained in this Declaration.
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`I provide this testimony based upon my personal knowledge. If called to testify, I would do so as
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`set forth in this Declaration.
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`2. I am the Registrant (“Registrant”) in this matter.
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`3. Petitioner is represented in this proceeding by counsels Eric Prager, Seth Gold, Margaux Nair,
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`Kate Hummel and Alexis Crawford Douglas.
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`4. Attached hereto as Exhibit A is a true and correct copy of the Wikipedia page for K&L Gates
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`LLP.
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`5. Attached hereto as Exhibit B is a true and correct copy of counsel Eric Prager’s resume on the
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`K&L Gates website.
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`6. Attached hereto as Exhibit C is a true and correct copy of counsel Seth Gold’s resume on the
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`K&L Gates website.
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`7. Attached hereto as Exhibit D is a true and correct copy of counsel Margaux Nairs’ resume on the
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`K&L Gates website.
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`1
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`

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`8. Attached hereto as Exhibit E is a true and correct copy of counsel Kate Hummel’s resume on the
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`K&L Gates website.
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`9. Attached hereto as Exhibit F is a true and correct copy of counsel Alexis Crawford Douglas’
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`resume on the K&L Gates website.
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`10. Attached hereto as Exhibit G is a true and correct copy of the ESTTA confirmation email
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`acknowledging my Motion to Quash of October 22, 2017, and showing that counsels Eric Prager
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`and Alexis Crawford Douglas received instant notification of my filing.
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`11. Attached hereto as Exhibit H is a true and correct copy of Seth Gold’s Sworn Declaration filed in
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`Case 2:17-mc-00127-SVW-JC with the District Court for the Central District of California, on
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`November 7, 2017.
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`12. Attached hereto as Exhibit I is a true and correct copy of Ndoema’s letter to Eric Prager dated
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`February 3, 2016 confirming production of six hundred and forty six (646) documents responsive
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`to Petitioner’s discovery requests.
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`13. Attached hereto as Exhibit J is a true and correct copy of Ndoema’s letter to Eric Prager dated
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`October 8, 2016 confirming production of six hundred and ten (610) documents responsive to
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`Petitioner’s discovery requests.
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct.
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`DATED: December 17, 2017
`
`
`
`_______________________
`
`NDOEMA (pro se)
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`2
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`Exhibit A
`Exhibit A
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`

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`K&L Gates - Wikipedia
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`12/13/17, 8)53 PM
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`K&L Gates
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`K&L Gates LLP is a US-based international law firm with offices in Asia,
`Australia, Europe, the Middle East, South America, and the United States.[4]
`Measured by headcount, it is the 8th largest law firm in the United States[5]
`and the 11th largest among law firms worldwide.[6] The firm delivers legal
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`services at both an individual office level and through nine broad firmwide
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`practice areas: Corporate and Transactional; Energy, Infrastructure and
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`Resources; Finance; Financial Services; Intellectual Property; Labor,
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`K&L Gates LLP
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`Headquarters
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`K&L Gates
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`Center
`Pittsburgh[1]
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`Employment and Workplace Safety; Litigation and Dispute Resolution; Real
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`No. of offices
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`45
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`Estate; and Regulatory and Policy, each of which also include a number of
`subject matter and industry-based practice groups.[7]
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`Contents
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`1
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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` Corporate governance
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` History
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` Notable ratings
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` Notable projects
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` Political contributions
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` Notable lawyers and alumni
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` References
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` External links
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`Corporate governance
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`As of March 2017, the leaders of K&L Gates are James Segerdahl (global
`
`(chairman, management
`managing partner) and Michael Caccese
`committee).[8] They replaced longtime chairman and global managing
`partner Peter Kalis, who had held that position since 1997.[9]
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`History
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`No. of attorneys Over 1800[2]
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`Major practice
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`General practice
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`areas
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`Key people
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`James Segerdahl
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`(global managing
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`partner), Michael
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`Caccese
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`(chairman,
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`management
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`committee)
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` US$1.17 billion
`(2016)[3]
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`Revenue
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`Date founded
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`1883 (Seattle,
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`U.S.A.)
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`Company type
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`Limited Liability
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`Website
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`Partnership
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`www.klgates.com
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`(http://www.klgate
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`s.com)
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`1858: London-based Nicholson Graham & Jones is founded
`1883: Preston Gates & Ellis is founded in Seattle,[10] emerging out of the private law offices of Harold Preston.
`1946: Pittsburgh-based Kirkpatrick & Lockhart is founded
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`https://en.wikipedia.org/wiki/K%26L_Gates
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`K&L Gates - Wikipedia
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`2005: Kirkpatrick & Lockhart and Nicholson Graham & Jones merge to become Kirkpatrick & Lockhart Nicholson
`Graham
`2007: On January 1, K&L Gates is formed in a merger between Kirkpatrick & Lockhart Nicholson Graham and
`Preston Gates & Ellis to form Kirkpatrick & Lockhart Preston Gates Ellis.[11] The name was later shortened to K&L
`Gates.
`2008: In January, K&L Gates combined with Hughes & Luce, a Dallas-based firm of 150 attorneys with offices in
`Austin, Dallas, and Fort Worth
`2008: In July K&L Gates combined with Kennedy Covington Lobdell & Hickman LLP, a North Carolina-based firm of
`200 attorneys with offices in Charlotte, Raleigh, and Research Triangle Park.[12]
`March 1, 2009: K&L Gates merged with Bell, Boyd & Lloyd, a Chicago-based firm with approximately 215 attorneys
`with offices in Chicago, San Diego and Washington, D.C.
`2013: K&L Gates combined with Australian national firm Middletons with offices in Melbourne, Sydney, Perth, and
`Brisbane
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`Notable ratings
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`In 2017 U.S. News ranked K&L as the best Law Firm in the category of Environmental Litigation.[13] The Financial Times
`labeled K&L among the "Most innovative North American law firms 2015: Compliance & technology".[14]
`
`K&L Gates received a "100 percent" on the 2018 Corporate Equality Index compiled by the Human Rights Campaign
`Foundation, an LGBT advocacy group.[15] In 2016 the "Yale Law Women" included K&L gates in the top ten "family-
`friendly" law firms.[16]
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`Notable projects
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`In September 2014, K&L Gates founded the "Cyber Civil Rights Legal Project". The project initially involves about fifty
`
`K&L lawyers working pro bono to assist about 100 victims of "revenge porn". According to the New York Times, the
`project is believed to be first of its kind at a major United States law firm.[17] By 2016, the project has aided hundreds of
`victims and has led to a handful of arrests.[18] In April 2017 the project secured an $8.9 million jury award for a King
`County couple, reportedly the largest award for non-celebrity targets of "revenge porn" to date.[19][20]
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`In 2016, K&L awarded a $10 million grant to Carnegie Mellon University (CMU) to establish the "K&L Gates Endowment
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`for Ethics and Computational Technologies". This new research center is to explore the ethics of artificial intelligence and
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`establish a biennial conference. The firm has provided legal services to CMU for decades; K&L Chairman Emeritus
`Charles J. Queenan Jr. once chaired CMU's Board of Trustees.[21][22]
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`In 2017, K&L announced it would create its own blockchain.[23]
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`Political contributions
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`According to the Center for Responsive Politics, K&L Gates was one of the top law firms contributing to federal candidates
`during the 2012 election cycle, donating $1.29 million, 52% to Democrats.[24] By comparison, during that same period
`Akin Gump Strauss Hauer & Feld donated $2.56 million, 66% to Democrats,[24] while oil conglomerate ExxonMobil
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`https://en.wikipedia.org/wiki/K%26L_Gates
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`K&L Gates - Wikipedia
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`donated $2.66 million, 88% to Republicans.[25] Since 1990, K&L Gates contributed $10.26 million to federal campaigns,
`and spent $1.25 million on lobbying since 1999.[26]
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`Notable lawyers and alumni
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`Dick Thornburgh, former Attorney General of the United States and two-term Governor of Pennsylvania[27][28][29]
`Bart Gordon, former twelve-term U.S. Congressman
`Slade Gorton, former two-term U.S. senator[30][31]
`Charles J. Queenan, Jr., chairman emeritus of firm; served as firm chairman from 1975 to 1990 (2014 recipient of
`Lifetime Achievement Award from The American Lawyer).[32]
`Peter J. Kalis, former chairman and global managing partner. In 2013, Kalis was named both one of the top legal
`innovators of the past 50 years by The American Lawyer magazine [33] and among the legal industry’s most
`innovative and groundbreaking thinkers on The National Law Journal’s inaugural list of “Top 50 Legal Business
`Trailblazers & Pioneers”[34]
`William H. Gates, Sr, attorney and philanthropist. One of the founders of Preston Gates & Ellis[35] (which merged to
`become K&L Gates). He is the father of Microsoft co-founder Bill Gates
`Bill Neukom, former American Bar Association president and managing partner of the San Francisco Giants [36]
`Michael S. Greco, former American Bar Association president[37]
`Michael C. Ormsby, U.S. Attorney for the Eastern District of Washington
`Jack Abramoff, former lobbyist, writer[38][39]
`Eric Schneiderman, the current New York Attorney General[40]
`Rick Santorum, former two-term U.S. Representative, former two-term U.S. Senator and 2012 Republican
`presidential candidate[41][42]
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`References
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`1. [1] (http://www.hoovers.com/company/KL_Gates_LLP/crryyi-1-1NJIC4-1NJIC5.html)
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`2. [2] (https://www.law.com/law-firm-profile?id=174&name=K%26L-Gates)
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`3. [3] (https://www.law.com/law-firm-profile?id=174&name=K%26L-Gates)
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`4. http://www.klgates.com/places/
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`5. "The NLJ 250:Our Annual Survey" (http://www.law.com/jsp/nlj/PubArticleNLJ.jsp?germane=1202489565842&id=1202
`546739310&slreturn=1). The National Law Journal. ALM Media Properties,