Law Orrices oF TIMOTHY L. O'REILLY 400 OCEANGATE SUITE 800 LONG BEACH. CALIFORNIA 90802 OFFICE 1569 197-2000 FACSIMILE S82 123-4477 ‘EMAIL: TLORGOREILLYLAWORG October 7, 2016 ‘Trung Si Luong 1505 West Tonia Court ‘Anaheim, CA 92802 Re: CEASE AND DESIST Unlawful Access to Computer and Phone Systems Public Disclosure of Private Information Annoying and Harassing Communications Slander of Business Name and Reputation Misappropriation of Trade Secrets/Documents/Customer Lists My Clients: Devin Benter and DEEVO LLC Dear Mr. Luong: My office represents Mr. Devin Benter and DEEVO LLC in connection with the above-referenced matters. You are notified to CEASE AND DESIST your unlawful (felonious) access to the computer and phone systems; the unlawful public disclosure of private information; your annoying and harassing emails, texts, and communications with my client, his family, employees, business associates and customers; your defamatory web postings designed to harm my client, his business names and reputation, and to immediately turn over all misappropriated trade secrets, business information, and customers list that you have unlawfully obtained. Itis my understanding that you have made unlawful access entries into my client's computer data base, phone systems, and made alterations to the same. The voice recordings of what appears to be you posing as one of my client’s employees in order to gain unlawful access to the computer phone system, likely show your commission of a felony under California Penal Code section 502. This matter has been reported to the police. Please be advised, that you should obtain the advice of competent counsel as to your rights against self-incrimination before providing any testimony on related matters. 1 intend cross-examine you on this potential felony conduct should the occasion arise. You have also failed to stop communicating electronically with my client and others whose information you have unlawfully obtained. You must stop this immediately. Please be advised that Penal code section 653m, makes annoying and harassing electronic communications a crime. Several of my client’s current customers have reported receiptCEASE AND DESIST October 1, 2016 Page 2 of false and misleading emails and other solicitations and contacts, being made by you to the present and prospective customers of my client. If true, the statements made by you regarding Mr. Benter, and DEVO LLC, and any subsidiary in which he may have an interest, are false, defamatory, constitute tortious interference with business, and as such, are actionable under California law. 1 also intend cross-examine you on this potential criminal conduct should the occasion arise. Further, investigation indicates that you have acquired certain trade secrets, business methods, programs, techniques, and processes, which includes confidential customer information and customer lists, acquired by you through improper means of either theft, misrepresentation, breach of a duty to maintain secrecy, or espionage through electronic or other means, all in violation of the California Uniform Trade Secrets Act. You must further CEASE AND DESIST use of information and other trade secrets (processes, data, forms, lists, email address, etc.) acquired from Mr. Benter and DEEVO LLC and immediately return the same to their exclusive possession. It does appear that your misappropriation of my client’s business information was done in a willful and malicious manner. Pursuant to California Civil Code section 3426.3, my client will be entitled to an award of exemplary damages (punitive), in addition to the amount proven for actual losses, for the damage you are attempting to cause. My client is preparing to commence a lawsuit against you in order to stop the continued felonious access, the annoying and harassing communications, the false and defamatory statements, and well as recover any losses due to your use of the misappropriated business information. Please be advised that they also intend to seek recovery of all attorneys” fees and other costs incurred pursuant to California Civil Code section 3426.2(c), and any other applicable statute. Please conduct yourself accordingly by complying with this cease and desist order. Also, you are required to immediately return all business property and customer information in your possession. Very Truly Yours, TIMOTHY L. O°REILLY, EsQ. TLOR: