1 LEWIS KOHN & WALKER, LLP

KENT M. WALKER (173700)

2 kwalker@lewiskohn.com

15030 Avenue of Science, Suite 201

3 San Diego, CA 92128

Phone: (858) 436-1333

4 Fax: (858) 436-1349

5 Attorneys for Defendants

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PACIFIC STORM, INC. and STORM SONDORS

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SUPERIOR COURT OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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SANTA MONICA DIVISION

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C.O. ENTERPRISES, INC. dba

AGENCY 2.0,

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Plaintiff,

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v.
PACIFIC STORM, INC. dba STORM
E-BIKE dba SONDORS E-BIKE, a
Delaware corporation; IVARS
SONDORS aka STORM SONDORS,
an individual; JON HOPP, an
individual; and DOES 1-100, inclusive,

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Defendant.

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DECLARATION OF STORM
SONDORS IN SUPPORT OF
DEFENDANTS PACIFIC
STORM, INC.S AND STORM
SONDORS OPPOSITION TO
PLAINTIFF AGENCY 2.0S
APPLICATION FOR
INJUNCTIVE RELIEF, OR
ALTERNATIVELY, A
PREJUDGMENT WRIT OF
ATTACHMENT

Hearing Date: May 6, 2015

Hearing Time: 8:30 a.m.
Dept.: WEP, Ctrm. P

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Hon. Nancy L. Newman

Complaint filed: April 9, 2015

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CASE NO.: SC124023

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-SC124023
DECLARATION OF SONDORS IN SUPPORT OF OPPOSITION TO APPLICATION FOR INJUNCTIVE RELIEF,
OR ALTERNATIVELY, A PREJUDGMENT WRIT OF ATTACHMENT

I, STORM SONDORS, declare as follows:

1.

I am an authorized representative of Defendant Pacific Storm, Inc. and

3 authorized to speak on its behalf. This declaration is in support of Defendants Pacific

4 Storm, Inc.s and Storm Sondors opposition to Plaintiffs Ex Parte Application for
5 an Order to Show Cause and Temporary Restraining Order and/or attachment
6 (Motion). Each of the facts stated herein are based on my own personal knowledge.
7 If called to testify, I could and would competently testify to each of the following
8 facts.
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2.

Pacific Storm, Inc. is using the funds raised via the Indiegogo funding

10 campaign that is the subject of Plaintiffs Motion to manufacture and prepare to ship
11 the eBikes ordered by backers of the campaign. There are thousands of backers and
12 about 10,000 eBikes on order from that campaign. The target for first deliveries of
13 eBikes is in May 2015. I am currently in China working on the manufacture of the
14 eBikes.

Exhibit

hereto

includes

excerpts

of

pictures

posted

to

15 https://www.indiegogo.com/projects/sondors-electric-bike as updates to backers

16 regarding this production process, including pictures of the bikes in production and
17 some pictures of me. If Pacific Storm, Inc. is not able to access and use the Indiegogo
18 funds, then that will prevent the manufacture and distribution of the eBikes to such
19 backers.
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3.

John Hopp is not an officer, director or other authorized representative

21 of Pacific Storm, Inc. John Hopp has not received funding from the Indiegogo.com
22 campaign that is the subject of Plaintiffs Motion. Mr. Hopp was not authorized to
23 sign the agreement asserted by Plaintiff on behalf of Pacific Storm, Inc.
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4.

25 campaign.

Not all of the Indiegogo.com funding has been disbursed from the
Pacific Storm, Inc. has paid Plaintiff $190,000. Plaintiff has failed to

26 provide information and services necessary for the campaign. Pacific Storm, Inc.
27 disputes any further amount it may owe Plaintiff.
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-1SC124023
DECLARATION OF SONDORS IN SUPPORT OF OPPOSITION TO APPLICATION FOR INJUNCTIVE RELIEF,
OR ALTERNATIVELY, A PREJUDGMENT WRIT OF ATTACHMENT

Exhibit A

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