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David Harris
4632 E. Caballero ST
Number One
Mesa, AZ 85205
(480) 297-9546
troll.assassins@cyber-wizard.com
Defendant Pro Se
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
AF Holdings, LLC
Plaintiff,
vs.
David Harris
Defendant.
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Case 2:12-cv-02144-GMS
The Honorable G. Murray Snow
Motion to Strike in Reply to
Plaintiffs Response to Defendants
Motion for Security
INTRODUCTION
C
omes now the Defendant, David Harris a proud, law abiding natural born citizen
of the United States of America, a layperson unschooled in the practice of law
having reached the age of majority and living in Mesa, Arizona County of Maricopa.
MOTION TO STRIKE
1. Under authority of FRCP 12(f), FRCP 11(b)(2) and LRCiv 7.1(m)(1), Defendant
moves this Court to strike from Plaintiffs reply to Defendants response to Plaintiffs
Motion for Order to Show Cause(ECF no.22) and Plaintiffs Response to Motion for
Security (ECF no.25) the following offending content therein that is redundant,
immaterial, impertinent, scandalous or misrepresents material facts, thus prejudicing the
Defendant by Plaintiff entering false and/or irrelevant facts into the record;
MEMORANDA
2. Plaintiff states: THE COURT HAS SUBJECT MATTER JURISDICTION,
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then the Plaintiff brings it home by quoting:
[a]nd (sic) all claims and causes of action of respect to any of the foregoing,
whether now known or hereafter to become known. (See Plaintiffs Complaint at
Exhibit B 1) (Emphasis added.). Plaintiff thus acquired the entirety of the copyright,
including the right to sue Defendant for his infringement of Plaintiffs copyright, by
virtue of the aforementioned assignment agreement (ECF no.22 page 3 lines21-24 &
page 4 line1).
A. This statement by Plaintiff must be stricken from the record as it has
no grounding in law, in fact is in violation of United States Copyright Law, is offensively
impertinent, scandalous and manufactures standing to bring this suit against Defendant
out of thin air. (See Silvers V. Sony Pictures Entertainment, Inc.402 F.3d 881 (2005) 9
th
Circuit)
B. On its face, the assertion by the Plaintiff that it has damages caused by the
alleged infringement that may be recovered in Federal Court is seen in the best light as
utterly incompetent or in the alternative fraud upon this court. The Plaintiff stipulates:
[T]hough Defendant correctly states that Plaintiff at the time of the alleged
infringement (Compl. 23.(cite added by Def.)) did not own the copyright [to Sexual
Obsession] (ECF no.22 page 3at 17)(See Defendant Exhibit A(cite added by
Defendant)). It is agreed then that the Plaintiff has no legal authority to bring this suit
against the Defendant. If Mr. Goodhue is merely incompetent, then he would have came
clean at this point citing 17 USC 501 and dismissing all claims against the Defendant
voluntarily, however that is not what Goodhue did. Instead he cites 17 USC 201 and
falsely claims: [P]laintiff thus acquired the entirety of the copyright, including the right
to sue Defendant for his infringement of Plaintiffs copyright, by virtue of the
aforementioned assignment agreement (ECF no.22page 3-4 at 24-1). Jurisdiction was
falsely established by Goodhue in his complaint and when it was brought to his attention,
he intentionally misrepresented to this court that his client had the right to claim
copyright infringement against Defendant in hopes of perpetuating his artifice against the
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Defendant using this Court as a tool for leverage. One would have to wonder why
attorney for the Plaintiff would take such a risk to prosecute a claim that it knows it can
not win. Even if judgement is in Plaintiffs favor, the odds of collecting even a thin dime
is minuscule. Defendant will bring to light the probable answer later in this brief. Even a
Pro Se Defendant unschooled in the principal of the law like myself knows that an
agreement between two porn peddlers trumps United States Code . . . NOT. This is
deliberate fraud on this Court by Mr. Goodhue.
C. United States Copyright Law 17 USC 501(b) lays out who may file suit
for infringement of a copyright as:
The legal or beneficial owner of an exclusive
right under a copyright is entitled, subject to the
requirements of section 411, to institute an action
for any infringement of that particular right
committed while he or she is the owner of it.
The statute is unambiguous and used by other district courts to establish lack of subject
matter jurisdiction, for example: Judge Dawson of the District of Nevada Court, in his
order to dismiss for lack of subject matter jurisdiction opines:
[F]ederal courts are required sua sponte to examine jurisdictional issues such
as lack of subject-matter jurisdiction. Bernhardt v. County of Los Angeles,
279 F.3d 862, 868 (9th Cir. 2002). If the Court determines at any time that it
lacks subject-matter jurisdiction, the Court must dismiss the action. See
Fed. R. Civ. P. 12(h)(3). Dismissal for lack of subject matter jurisdiction is proper
if the complaint, considered in its entirety, fails to allege facts that are sufficient to
establish subject matter jurisdiction. In re Dynamic Random Access Memory
(DRAM) Antitrust Litigation, 546 F.3d 981, 984-85 (9th Cir. 2008).
Section 501(b) of the 1976 Copyright Act (Act) establishes who is legally
authorized to sue for infringement of a copyright:
The legal or beneficial owner of an exclusive right under a
copyright is entitled, subject to the requirements of section
411, to institute an action for an infringement of that particular
right committed while he or she is the owner of it.
17 U.S.C. 501(b). Therefore, to be entitled to sue for copyright infringement,
the plaintiff must be the legal or beneficial owner of an exclusive right under
a copyright. See Silvers v. Sony Pictures Entmt, Inc., 402 F.3d 881, 884
(9th Cir. 2005). If the plaintiff is not a proper owner of the copyright rights,
then it cannot invoke copyright protection stemming from the exclusive
rights belonging to the owner, including infringement of the copyright. Id.
(quoting 4 Business and Commercial Litigation in Federal Courts, at 1062
65.3(a)(4) (Robert Haig ed.)). Section 106 of the Act defines and limits the
exclusive rights under copyright law.1 Id. at 884-85. While these exclusive
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rights may be transferred and owned separately, the assignment of a bare
right to sue is ineffectual because it is not one of the exclusive rights. Id.
Since the right to sue is not one of the exclusive rights, transfer solely of
the right to sue does not confer standing on the assignee. Id. at 890.
Additionally, the bare assignment of an accrued cause of action is
impermissible under [the Act]. Id. One can only obtain a right to sue on a
copyright if the party also obtains one of the exclusive rights in the copyright.
See id.(Righthaven v Hyatt no.2:10-cv-01736-KJD -RJJ ECF 42 at 2-4
thru 3-8)...
D. Plaintiffs assertion that this or any Court has subject matter jurisdiction
falls short of being truthful, accurate or correct, therefore must be stricken from the
record.
Lack of Subject-Matter Jurisdiction. If the court
determines at any time that it lacks subject-matter
jurisdiction, the court must dismiss the action
(emphasis added)(FRCP 12(h)(3)).
Plaintiffs claims against the Defendant must be summarily, immediately and permanently
dismissed.
3. Plaintiff asserts: Defendant in the instant action seems to have forgotten how to
properly conduct himself in society, much less as a participant in U.S. District Court.
Neither Defendants lack of familiarity with the law, nor his financial situation, excuses
the lack of self-control Defendant has displayed (ECF no.22 page 5 lines 6 to 10).
A. This statement by the Plaintiff is utterly fascinating in its absolute absence of
substance and must be stricken from the record as it is a violation of FRCP 11(b) a direct
misrepresentation of a material fact.
B. Plaintiff asserts information as though it has substance, as if he has personal
knowledge of what he is talking about, he does not! The burden of proof lies with the
accusing party. I challenge Mr. Goodhue to show prima facie evidence to support that
Defendant ever knew how to properly conduct himself in society, for all he knows I may
be the epitome of pristine social etiquette, I guess some people really know how to bring
out the worst in people. Considering what the Plaintiff is putting the Defendant through by
filing the instant case for improper reasons and knowing or should know the allegations
are false and the suit is frivolous, the Defendant being so personally attached to the case
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has shown a perfectly acceptable amount of restraint, if anyone has displayed a lack of
self-control it is the Plaintiff by prosecuting this case without a cause of action, by
repeatedly trying to stifle Defendants First Amendment right to express himself by trying
to have Defendant sanctioned for trivial reasons, compared to his acts and omissions.
If the Plaintiff had any sense of self control at all, then he would not argue using clever
fallacies and he would be able to open his mouth once in a while without lying. Its one
thing to have to defend oneself against a claim that was creatively manufactured by a
lawyer, who is educated and experienced in the practice of the law, but it is another thing
all together to have to babysit a grown man who can not be trusted to perform his job with
a little good faith!
4. Plaintiffs main argument, propounded in sections: LEGAL STANDARD
and ARGUMENT I. and II., is a red herring absolutely irrelevant to Defendants
Motion for Security. Therefore must be stricken from record for the following reasons;
A. Mr. Goodhue has confused attorney fees with litigation costs. Plaintiffs assertion
that Defendant is seeking a security bond for attorney fees is a complete fabrication,
completely detached from reality. Defendant NEVER thought he was entitled to
attorneys fees, any assertion otherwise is incorrect. Defendant stated in his Motion for
security, Defendant realizes that he can not calculate fees and costs based on lawyers
compensation ( Mot. at 6). Regardless of Mr. Goodhues opinion Defendant expects to
be fully compensated for his participation in Defending himself from the Plaintiff in this
frivolous suit. After all it is the attorney of record who drug me into court claiming
infringement of his clients copyright, when the copyright in question did not even belong
to him and this after suing Defendant in the District of Columbia for the exact same cause
of action, failing to prosecute that claim, which is now full adjudicated. It is a sheer piece
of legal genius how Mr. Goodhue creates a nexus between Defendant and attorney fees:
It is clear, judging by the outrageous amount requested that what Defendant seeks in
his Motion is security for attorneys fees... (Resp. at page 2 lines 9-10). No Your
Honor it is not, what it is, is Plaintiff asserting his opinion as though it is fact. If Mr.
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Goodhue does not know the different between litigation costs and attorney fees, then he
could not possibly know the difference in costs between the two. Therefore any claim
Plaintiff made in his response regarding Defendant seeking attorney fees is offensive,
irrelevant, impertinent, immaterial and frankly a down right lie, therefore they must be
stricken from the record.
B. Speaking of the Defendant, Goodhue states: [H]e is not entitled to attorneys
fees or any compensation for his participation in this case at any rate (Resp. at page 2, 15-
16). Then on the very next page of his response: [A]t this point, Plaintiff estimates
Defendants actual costs in this case to amount to $10, and that is a liberal estimate(Resp.
at page 3,14-15). This reveals a very disturbing mind set displayed by the Plaintiff, the
fact that he agrees Defendant has actual costs in this suit, but is not entitled to
compensation when and if he prevails, shows an absolute disdain for the Defendant and
the rule of law. That explains how he can knowingly file a frivolous lawsuit against
Defendant knowing full well his complaint does not meet the minimum legal standard and
not fear retribution from this Court or is there a more sinister reason for Plaintiff filing this
action against Defendant? Defendant thinks the latter, and this is why:
5. This statement by Plaintiff is most troubling: Defendants final assertions
regard criminal action perpetrated against the Defendantjust merely stating fact, albeit
not introduced into evidenceyet. (ECF No. 23 at 5.). As Defendant has not provided
any evidence, or even made a concrete statement as to what sort of criminal conduct he is
alleging, Plaintiff finds no avenue by which respond (sic) to Defendants unsubstantiated,
undisclosed accusations... (Resp. at 4, 20-24). This statement combined with Mr.
Goodhues answer to Defendants Counter Claim 7 and 8 clearly shows the Court that
Mr. Goodhue will say anything, regardless of truthfulness or the lack there of, as long as
it is in line with his goal, the end befits the means. This is made evident by:
6. Mr. Goodhue now says he knows nothing about being accused by the Defendant of
any criminal acts and finds no avenue by which to respond, however he did respond to this
accusation in his answer to Defendants Counter Claim by denying it, indicating that he
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had sufficient knowledge to form an opinion (id at ECF 17 at 7 and 8). Now he does not
have that knowledge any more which is puzzling to say the least.
7. Two days before the Plaintiff filed his response with the Court Mr. Goodhue and
I had an email exchange (Def. exhibit B) were I agreed to his conditions to meet for case
management provided Paul Duffy National Counsel (ECF 12.1) for the Plaintiff (Prenda
Law, Inc.) would be in attendance, I requested Goodhue let me know ASAP if Duffy was
not going to attend. It is now five days later and no word from Goodhue, causing any
reasonable thinking person to assume that Goodhue has already talked to Duffy, was
instructed not to contact me and because I mentioned in the email Duffys action I labeled
as criminal in the Counter Claim, after a discussion about it with Duffy, Goodhue was
instructed by Duffy to now deny all knowledge of any criminal allegations whatsoever or
in the alternative Goodhue is so incompetent that he just could not remember well enough
to connect the dots.
8. Paul Duffy sent me an extortion letter, disguised as a settlement offer on December
29, 2011. Duffy stated : [O]n 6/3/2011 12:49:34 AM (UTC), our agents observed the IP
address with which you are associated illegally downloading and sharing with others via
the BitTorrent protocol the following copyrighted file(s):
Sexual Obsession
The ISP you were connected to: Cox Communications
Your IP Address you were assigned during your illegal activity: 70.176.202.3
We have received a subpoena return from your ISP confirming that you are indeed the
person that was associated with the IP address that was performing the illegal
downloading of our client's content listed above on the exact date(s) listed above... (Def.
Exhibit C-1). Notice that the DC case is identical to the instant case insofar as the alleged
infringement is upon the same work' (Sexual Obsession), from the same IP address
(70.176.202.3), the exact date and time (6/3/2011 12:49:34 AM (UTC) and the exact cause
of action (copyright infringement) Plaintiff misrepresented that it had a legal right to sue,
when in fact it did not own the copyright at the date and time of the alleged infringement.
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The Plaintiff was granted early discovery to subpoena the ISPs of 1,140 John Doe
defendants of which the Defendant was one (see Exhibit G) to harvest personal
information so the Plaintiff could send letters to the account holders in an attempt to extort
money from them, as you can see from the case docket (AF Holdings v Does 1-1140
no.1:11-cv-01274-RBW District of Columbia) Plaintiff did not name and serve a single
defendant. The personal information was illegally obtained by Plaintiffs scheme of
misrepresenting to the Court that it had a right to bring a cause of action which it did not,
as it did not own the copyright in question at the time of the alleged infringement and the
Plaintiff illegally used that information to name the Defendant now in the instant case to
further advance Plaintiff's criminal enterprise, only this time in the hopes of creating an
affirmative defense for perpetrating a felony on the Defendant:
9. Paul Duffy in his extortion letter to the Defendant continues: ...On July 13, 2011
we filed a lawsuit in the United States District Court for the District of Columbia against
several anonymous digital pirates (AF Holdings LLC v. Does 1-1 , 140). Under the
Federal Rules of Civil Procedure, our lawsuit against you personally will not commence
until we serve you with a Complaint, which we are prepared to do if our settlement
efforts fail... (Emphasis added (Exhibit C1-2)).
10. Then on January 30th, 2012 Defendant received another extortion letter from
Prenda Law, Inc., this time from an extortionist named Joseph Perea, who stated: "[I]f
our office does not hear from you by February 13, 2011, we will presume that you are not
interested in resolving this matter through settlement..." (Exhibit D) both of these letters on
there face was nothing more that an attempt to use the threat of a law suit to gain leverage
on the Defendant to extort $3,400.00 as they had already failed to prosecute under FRCP
Rule 4(m) as Defendant would just motion the court to dismiss for failure to prosecute.
11. Defendant filed charges against the Plaintiff with the Mesa Police Department
(Exhibit F) and informed Prenda Law, Inc. of such in a letter to Joseph Perea dated
February 2
nd
, 2012 (Exhibit E). Defendant is of the opinion that Plaintiff discovered that
the charges filed against them were legitimate, so Plaintiffs attorney played fast and
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loose with their clients money by filing eight frivolous lawsuits in the District of Arizona
in hopes of at least one of the cases defaulting so Plaintiff could spin that win into the only
affirmative defense for Theft by Extortion: ARS 13-1804(B): [I]t is an affirmative
defense to a prosecution under subsection A, paragraph 5, 6 or 7 that the property
obtained by threat of the accusation, exposure, lawsuit or other invocation of official
action was lawfully claimed... It is my belief that Mr. Duffy is getting a little nervous as
the statute of limitation for the state to file criminal charges against him is less than sixty
days away.

CONCLUSION
12. Considering the aforementioned assertions of the Defendant, it becomes
clear that Plaintiff has utterly failed at showing the smallest bit of good faith and is in this
game, not to defend its client, not to seek justice, but to use the Federal Judiciary, to
leverage the Court in such a fashion that they will be able to pull their fat out of the fire
before it is too late!
13. For all the reasons stated herein Defendant PRAYS:
That this Court grant Defendants Motion for Security and order the
Plaintiff to post an amount adequate to guarantee their performance in this
lawsuit.
That this Court have stricken from the record all the offensive content
aforementioned.
That this Court examine Plaintiffs claim to having the capacity to sue
for copyright infringement of the work on the date of the alleged
infringement, find that Plaintiff did not establish subject matter jurisdiction
and release this defendant from the web of the Plaintiff, once and for all.
That this Court advise the Judges of the other seven cases contained in
the Defendants Answer (ECF no. 14, 4 at 14) of your findings regarding
Plaintiffs lack of standing, as each and everyone one of these cases are
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identical in Plaintiff, the work and that at the time of the alleged
infringement the Plaintiff was not the copyright owner.

That this court sanction the Plaintiffs counsels Law Firm Prenda

Law, Inc. as to what would be fair, just and proper.



I swear or affirm and declare or certify, verify or state under penalty of perjury that the

foregoing is true and correct so help me God.

Executed this 10
th
day of December, 2012.



By: /s/ David Harris

David Harris
4632 E. Caballero St.
Number One
Mesa, Arizona 85205

Defendant Pro Se




One Attachment, Index of Exhibits







Page 10 of 11
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CERTIFICATE OF SERVICE
I hereby certify that on this 30
th
day of November, 2012, a copy of the foregoing
was filed electronically and served upon the following by operation of the Courts
electronic filing system.
Steven James Goodhue (#029288)
Law Offices of Steven James Goodhue
9375 East Shea Blvd., Suite 100
Scottsdale, AZ 85260
Telephone: (480) 214-9500
Facsimile: (480) 214-9501
E-Mail: sjg@sjgoodlaw.com
By: /s/ David Harris
Page 11 of 11
Case 2:12-cv-02144-GMS Document 26 Filed 12/10/12 Page 11 of 11
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Case 2:12-cv-02144-GMS
INDEX OF EXHIBITS
Exhibit Description
A United States Copyright Office, Public Catalog, Sexual Obsession
B December 4
th
, 2012, Email to Goodhue, Demanding Duffy attend CMC
C-1 December 29
th
,2011, Extortion letter from Paul Duffy, Page 1
C-2 December 29
th
, 2011, Extortion letter from Paul Duffy, Page 2
C-3 December 29
th
, 2011, Extortion letter from Paul Duffy, Page 3
D January 30
th
, 2012, Extortion letter from Joseph Perea
E February 2
nd
, 2012, Reply to Pereas Extortion letter
F January 6
th
, 2011, DR number for complaint filed with Mesa PD
G September 30
th
, 2011, Mass subpeona notice from Cox Communications
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 1 of 10
WebVoyage Record View 1
http://cocatalog.loc.gov/...Search_Code=TALL&CNT=25&PID=l6LbJNNMuVK2Xa2tP4g0d99LMGBAJ&SEQ=20121105125230&SID=1[11/5/2012 10:53:18 AM]
Publ i c Cat al og
Copyright Cat alog (1978 t o present )
Search Request : Left Anchored Tit le = sexual obsession
Search Result s: Displaying 5 of 6 ent ries

Sexual obsessi on. PA 1- 725- 120.
Type of Wor k: Recorded Document
Document Number : V3608D727
Dat e of Recor dat i on: 2011-10-03
Ent i r e Copyr i ght Document : V3608 D727 P1-3
Dat e of Execut i on: effect ive as of 12Jun11; dat e of cert .: 29Sep11
Regi st r at i on Number Not Ver i f i ed: PA 1-725-120.
Ti t l e: Sexual obsession. PA 1-725-120.
Not es: Copyright assignment agreement .
Par t y 1: Heart breaker Films, Heart breaker Product ions, I nc., Raymond
Rogers & XSC Digit al Corporat ion.
Par t y 2: AF Holdings, LLC a.k.a. AF Films, LLC.
Names: Rogers, Raymond
Heart breaker Films
Heart breaker Product ions, I nc.
XSC Digit al Corporat ion.
AF Holdings, LLC
AF Films, LLC.

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liiJail.com '" '" <troll.assasslns@cyber-wlzard.com>
Subject RE: AF Holdings, L.L.C. v. David Harris, Case No.; 2:12-CV-
02144.
From:
To:
Date:
troll.assassins@cyber-wizard.com
sjg@sjgoodlaw.com
12/04/12 05:16PM
Mr. Qood""' I d be at oJii:e MOllday Deceldlef 17, at 2:00pm. I baw ODe dCIDIDd.
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bw 1D tubpoeD& hiD ... D&vil.
Original Message ---
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Sent: 12/04112 12:00 PM
To: trull.assasslnsOcyber-wlzani.CDm
Subject: RE: 1tf Holdings, L.L.C. v. Dllvld Han111, Case No.; 2 :12<'Ml2144.
Dear Mr. HarTle: Altadled llleaM hi my lettw 4. 2012.
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Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 3 of 10
B
renda Law,n ..
Pro t ecting I n t ellectual P roperty
December 29, 2011
VIA U.S. MAIL
David Harris
4632 E Caballero Street, Apt 1
Mesa, AZ 85205
Re: AF Holdings LLC v. Does 1-1,140
1:11-cv-01274 RBW, Ref#8569
Dear David Harris:
Prenda Law Inc. has been retained by AF Holdings LLC to pursue legal action against people who
illegally downloaded their copyrighted content (i.e., "digital pirates"). Digital piracy is a very serious
problem for adult content producers, such as our client, who depend on revenues to sustain their
businesses and pay their employees.
On 6/3/2011 12:49:34 AM (UTC), our agents observed the IP address with which you are associated
illegally downloading and sharing with others via the BitTorrent protocol the following copyrighted
file(s):
Sexual Obsession
The ISP you were connected to: Cox Communications
Your IP Address you were assigned during your illegal activity: 70.176.202.3
We have received a subpoena return from your ISP confirming that you are indeed the person that
was associated with the IP address that was performing the illegal downloading of our client's content
listed above on the exact date(s) listed above
On July 13, 2011 we filed a lawsuit in the United States District Court for the District of Columbia
against several anonymous digital pirates (AF Holdings LLC v. Does 1-1 , 140). Under the Federal
Rules of Civil Procedure, our lawsuit against you personally will not commence until we serve you
with a Complaint, which we are
Fax: 3 12.893. 5677
Fax: 305 . 748. 2 103
161 N Cl a rk St., Suit e 320 0, C hi cago, IL 6060 1
11 11 Lincoln Rd. , Suite 40 0, Mi ami B each, FL 33139
www.wefightpirac y . com
T el : 312.880. 91 60
T el : 3 05. 748 . ] 'n-
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 4 of 10
C-1
prepared to do if our settlement efforts fai l. While it is too late to undo the illegal file sharing
associated with your IP address, we have prepared an offer to enable our client to recover damages
for the harm caused by the illegal downloading and to allow both parties to avoid the expense of a
lawsuit.
Under the Copyright Law of the United States, copyright owners may recover up to $150,000 in
statutory damages (in cases where statutory damages are applicable, which may or may not be the
case here) per infringing file plus attorney' s fees in cases, whereas here, infringement was willful. In
it least one case where the Copyright Law has been applied to digital piracy and statutory damages
were applicable, juries have awarded over $20,000 per pirated file. During the RIAA's well-publicized
campaign against digital music piracy, over 30,000 people nationwide settled their cases for amounts
ranging from an average of $3,000 to $12,000. More recently, on December 22, 2010, a case in
which a defendant was accused of illegally downloading six works via BitTorrent, a settlement was
reached for $250,000.
In light of these factors, we believe that providing you with an opportunity to avoid litigation by working
out a settlement with us, versus the costs of attorneys' fees and the uncertainty associated with jury
verdicts, is very reasonable and in good faith.
In exchange for a comprehensive release of all legal claims in this matter, which will enable you to
avoid becoming a named Defendant in our lawsuit, our firm is authorized to accept the sum of
$3,400.00 as full settlement for the claims. This offer will expire on January 12, 2012, at 4:00 p.m.
CST. If you reject our settlement offers, we expect to serve you with a Complaint and commence
litigation.
To reiterate: if you act promptly you will avoid being named as a Defendant in the lawsuit. You may
pay the settlement amount by:
(a) Mailing a check or money order payable to "Prenda Law Inc. Trust Account" to:
Prenda Law Inc.
1111 Lincoln Rd., Suite 400
Miami Beach, Florida 33139;
(b) Completing and mailing/faxing the enclosed payment authorization to:
Prenda Law Inc.
1111 Lincoln Rd., Suite 400
Miami Beach, Florida 33139
Facsimile: (305) 748-2103.
Be sure to reference your case number and your "Ref#" on your method of payment. Regardless of
your payment method, once we have processed the settlement, we will mail you your signed Release
as confirmation that your payment has been processed and that you have been released from the
lawsuit.
Legal Correspondence - Settlement Purposes Only- Not Admissible Under FRE 408
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 5 of 10
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Please consider this letter to constitute formal notice that until and unless we are able to settle our
client's claim against you, we demand that you not delete any files from your computer or any other
computers under your control or in your possession. If forced to proceed against you in a lawsuit, we
will have a computer forensic expert inspect these computers in an effort to locate the subject content
and to determine if you have deleted any content. If in the course of litigation the forensic computer
evidence suggests that you deleted media files, our client will amend its complaint to add a "spoliation
of evidence" claim against you. Be advised that if we prevail on this additional claim, the court could
award monetary sanctions, evidentiary sanctions and reasonable attorneys' fees. If you are
unfamiliar with the nature of this claim in this context, please consult an attorney.
We strongly encourage you to consult with an attorney to review your rights in connection with this
matter. Although we have endeavored to provide you with accurate information, our interests are
directly adverse to yours and you should not rely on the information provided in this letter for
assessing your position in this case. Only an attorney who represents you can be relied upon for a
comprehensive analysis of our client's claim against you.
Enclosed, please find a Frequently Asked Questions sheet, a payment authorization form and a
sample of the Release that you will receive. We look forward to resolving our client's claim against
you in an amicable fashion, through settlement.
Sincerely, ~
' ~ ~
Attorney and Counselor at Law
Enclosures
Legal Correspondence- Settlement Purposes Only- Not Admissible Under FRE 408
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 6 of 10
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renda Lawlnc.
Pro r ecring l n r e l lecrual P roperty
January 30, 2012
VIA U.S. MAIL
David Harris
4632 E Caba!!ero Street, .A.pt
Mesa, AZ 85205
davenewworld@yahoo.com
Re: AF Holdings LLC v. Does 1-1,140
1:11-cv-01274 RBW, Ref#8569
Dear David Harris:
On December 29, 2011 our office sent you correspondence regarding the above-referenced copyright
infringement lawsuit that was filed on July 13, 2011 in the Northern District of Illinois. Our office has
also attempted, in good faith, to contact you in an effort to resolve this matter amicably and avoid
litigation. To date, we have not been able to resolve this matter with you.
We recommend that you retain an attorney to assess your rights and liabilities in this matter. If you
do so, please provide them with this letter so they may contact our office. If our office does not hear
from you by February 13, 2011, we will presume that you are not interested in resolving this matter
through settlement.
Sincerely,


Attorney and Counselor at Law
Fax: 3 12.893 . 5677
Fax: 305.74 8.2103
16 1 N Cl ark St. , Suite 3200, Chicago, IL 60601
111 1 Li nco ln Rd . , Su ite 400, Miami Beach , FL 33 139
www.wefightpiracy.com
Tel : 312. 8 80.9160
Tel : 30 5 . 748.2102
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 7 of 10
D
David Harris
4632 E. Caballero St.
Mesa, AZ 85205
davenewworld@yahoo.com
February 2, 2012
Joseph Perea
Prenda Law, inc.
Suite 3200
Chicago, IL 60601
RE: CLARIFICATION
Dear Joseph Perea,
I am in receipt of your letter dated January 30, 2012. I have decided to comply with your request, however I feel it
necessary to point out irregularities in your letter:
The lawsuit you described does NOT exist in the Northen District of Illinois.
Your settlement offer does NOT CONFORM to Federal Rules 2 and 3.
Your settlement offer DOES fall under Arizona Law: ARS 13 1804:
A. A person commits theft by extortion by knowingly obtaining or seeking to obtain property
or services by means of a threat to do in the future any of the following:
5. Accuse anyone of a crime . . .
C. Theft by extortion as defined in subsection A, paragraph 1 is a class 2
felony. Otherwise, theft by extortion is a class 4 felony.
You sir are a FELON and a CRAVEN.
That having been said, here is your instructions for payment: I have placed thirty-four crisp one hundred dollar
bills on my cocktail table in my living room, you can have it, however I will not be intimidated by your insolence,
so if you want it come and get it the way any other reprobate, street thug would. You have to rob me honestly(sic).
Be advised Mr. Perea when you break into my house you do so in the Great State of Arizona, and you do so at your
own peril Mr. Chicago way!
If you have any questions please direct them to:
Mesa Police Department
Officer M. Moore Badge No. 16889
RE: Complaint No. 20120060371
110 N. Robson
Mesa, AZ 85201

Officer Moore is working with me locally to resolve this matter. Be advised Mr. Perea that I also have a complaint
filed against Prenda Law, inc. with the FBI Cyber Crime Unit that your name will be added to.
I look forward to your filing a complaint against me personally. The proper venue is The United States District
Court for the State of Arizona. You will face me Pro Se. I do not require legal counsel to utterly destroy you in a
court of law you stupid mother fucker.
Sincerely,
David Harris
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 8 of 10
E
UciTYOF
-MESA
Victim Services Unit
Mesa Police Department
Your Rights as a
Crime Victim
The Oty of Mesa regrets that you 11M been the victim
We to give you
ycJUr nghts as a VJctem and about the serw:es avaJiable
to assist you. If you-iOiSQ to give adcfltional information
on your-initial report, call (480} 644-2324. To
chec_ _?Q the case-after thirty days, call
il ... .
r . ot/t!&/;
Mesa Police Report Number Date
Type of Crime
, C4Jrreot The identified section within this
will giW you more specifiC information.
rJ Initial report only.
D Citation issued.
Appearance date and time within 24
l:J Submitted to County Attorney as felony.
I:J Submitted to Oty Prosecutor as misdemeanor.
I] Juvenile referred but not detained.
0 Felony arrest.
Misdemeanor arrest.
GJ Juvenile detained.
Suspect(s) Information:
Name(s) ____________ _
Date(s) of Birth-----------
Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 9 of 10
F
Date:09/30/20 11
MASS SUBPOENA NOTIFICATION
David Harris
4632 E Caballero Street, Apt 1
Mesa, AZ 85205
Target Details: IP Address 70.176.202.3 on 06/03/2011 12:49:34 AM
Dear Customer:
Neustar is the designated agent of Cox Communications authorized to respond to subpoenas,
search warrants, and court orders for the production of subscriber records.
It is the policy of Cox Communications to notify a subscriber that a subpoena has been received
for the subscriber's records.
Accordingly, please be advised that on 09113/2011 a Civil Proceeding Subpoena Request was
received from John Steele, Attorney for Plaintiff, Phone # (305)-748-21 01. Cox Communications will
comply with this subpoena on 10/3 1/2011 unless we receive legal documents that delay or terminate the
process on or before I 0/30/2011.
Cox Communications is not a party to this lawsuit and has' no information about the basis for the
subpoena. However, Cox Communications has created a webpage with some explanatory information
about the background of this litigation. For more information, please access the below listed link.
http://support.cox.com/sdccommonlasp/contentredirect.asp ?sprt _ cid=c8bc8c l a-2a 73-4 755-87 5f-155a I e3 5d440
Any questions you may have about the subpoena itself should be referred to John Steele, Attorney
for Plaintiff, Phone # (305)-748-21 01. If you have a need to contact NeuStar about this letter or our
procedure, please contact us at (877) 510-4357, Option 4. To better enable us to provide prompt
assistance, please refer to case# AD25768 when calling.
Angelique Dade
Authorized Agent for Custodian of Records
Cox Communications
If you would like to authorize the release of your records immediately, please sign in the space provided
below and fax this page to us at ( 571) 4 34-3401.
Customer Signature Date
tleustar. Inc. : 46000 Centet .)ak Flaz : ~ Sterllnv, V P. :0"16G i t el: 877 51 0-4357 fax: 57 1 434-34 01 or 5 li 434 -3402 'lNN .. neustar. biZ

Case 2:12-cv-02144-GMS Document 26-1 Filed 12/10/12 Page 10 of 10
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