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Declaration of William M. Bryner: Reynolds Innovations v. Addision

Declaration of William M. Bryner: Reynolds Innovations v. Addision

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Published by Staci Zaretsky
Declaration of William M. Bryner: Reynolds Innovations v. Addision
Declaration of William M. Bryner: Reynolds Innovations v. Addision

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Published by: Staci Zaretsky on Jan 21, 2014
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02/14/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
REYNOLDS INNOVATIONS INC., Plaintiff, vs. CHANCE ADDISON, individually and d/b/a “ADDISON E-CIGARETTES LLC,” “ADDISONECIG.COM,” “SPOKANEECIG.COM,” “MILEHIGHECIG.COM,” and “LCP INC.”; and ADDISON E-CIGARETTES LLC d/b/a “ADDISONECIG.COM,” “SPOKANEECIG.COM,” “MILEHIGHECIG.COM,” “LCP INC.,” and “VICIOUS E-LIQUID,” Defendants.  _________________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 1:13-CV-210
THIRD DECLARATION OF WILLIAM M. BRYNER
I, William M. Bryner, declare under penalty of perjury as follows: 1. My name is William M. Bryner. I am a partner in the law firm of Kilpatrick Townsend & Stockton LLP (“Kilpatrick Townsend”), and am an attorney licensed to practice in the State of North Carolina. I have been admitted to practice  before this Court. I am one of the attorneys who has been involved in and responsible for the representation of Plaintiff Reynolds Innovations, Inc. (“RII”) in the above-captioned litigation. The statements contained herein are made of my own personal knowledge.
Case1:13-cv-00210-NCT-JEPDocument41Filed01/16/14Pae1of6
 
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2. On October 7, 2013, RII filed its motion for default judgment and related  papers against Defendant Addison E-Cigarettes LLC (“AEC LLC”), due to AEC LLC’s failure to file an answer or other responsive pleading through duly licensed counsel. (Dkt. Nos. 24, 25, and 26) 3. Since RII’s October 7, 2013 filings, and in addition to the numerous filings made with the Court, the CEO of AEC LLC, Defendant Chance Addison, has directed numerous communications to my attention by telephone and by email. True and accurate copies of email messages that I have received from Mr. Addison since October 7, 2013 are attached hereto as
Exhibits 1, 2 and 3
. 4. In addition, on December 11, 2013, I received a telephonic voice-mail message from Mr. Addison that said as follows: Hey Bill, this is Chance Addison. Say it has been really quiet over here and I am kind of missing the entertainment. Can you whip up some  paperwork for me so I can tear you a new one in court again, buddy? Thanks. Oh, hey, that Christmas present dude, I know you’re not going to  be able to top that right? You can try, but go ahead. Hey, I just don’t think you are going to be able to do it, buddy. 5. On December 12, 2013, I received a telephonic voice-mail message from Mr. Addison that said as follows: Bill, this is the point where I am going to quote our first and only  phone conversation verbatim. I believe you said something to the effect of “my client has extensive experience dealing with people like me.” The “me” part is a little bit of a paraphrase, but the “your client has extensive experience,” that part is word for word, buddy. You want to retract that statement now? (Laughter) 6. On December 18, 2013, I received a telephonic voice-mail message from Mr. Addison that said as follows:
Case1:13-cv-00210-NCT-JEPDocument41Filed01/16/14Pae2of6
 
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Mr. Bryner, this is Chance Addison calling once again to bolster my entertainment being received from our court case 1:13CV210.
 Reynolds  Innovation v. Chance Addison et al.
 As it turns out the government is extremely, extremely bad at communication between agencies and as such is giving me multiple opportunities to enjoy this case. I just wanted to let you know. Also that there is no possible way that you could ever give Judge Peake a finer Christmas gift than that which she will be receiving from me today. Probably within the next hour and a half I would say. And so, I cannot wait for 2014, buddy. We are going to have so much fun together. 7. On January 2, 2014, I received a telephonic voice-mail message from Mr. Addison that said as follows: Hey Bill, this is Chance Addison over here in Washington state for a few more days anyway. So I don’t know if you heard the rumor yet, but it is true that I am writing a book and it does now feature your client’s humiliation and your complete defeat in court. You may have noticed that I did launch a non-profit. You might remember that I did promise that I did  promise that I was going to whip the shit out of your fucking client, humiliate you. I think I finally succeeded in that. I am really disappointed that you’ve not yet really given me much of a fight, but I am taking really great care of myself and I am hoping to live a long time so we can duke it out for a couple of more decades, buddy. I am also studying up on a few areas of the law which you probably still hold an advantage on me for a little while, anyway. Call me if you want to, you know, figure out how we are going to make this go away. I got a lot of experience at making people like you go away. 8. On January 10, 2014, I received a telephonic voice-mail message from Mr. Addison that said as follows: Hey, Bill, this is Chance Addison. Say I am in your neighborhood and I wanted to find out if you wanted to have another crack at mediation instead of more of the same from me. I believe you have my cell phone number, but I’ll go ahead and leave it for you anyway, 208-704-0409, and go ahead and leave me a message and I’ll get back with you right away. Thanks, bud. 9. On the morning of January 15, 2014, at approximately 8:50 a.m., the
Case1:13-cv-00210-NCT-JEPDocument41Filed01/16/14Pae3of6

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