Os '.SSrYC','TNO r (me, e FOfCO1JRT USE ONLY
Maurice R. Mitts/Cat ijn M. Plump (#156777)
MIFFS MILAVEC, LLC
Two Logan Square, 12th Floor, 18th & Arch Streets
Philadelphia, PA 19103
TLIONENO,: (215) 569-1 800 FAXISO, (°Pr (215) 569-1822
occ i(:': mmias@mifls1aw.com
CTTORt:L\" 0R TIar): Defendant Gap International, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA
STREET ADDRESS: 1225 Fallon Street
MdUNG ADDRESS:
nT'Ysozpcooe Oakland, CA 94612
BRANCH NAME Rene C. Davidson Courthouse
PLAINTIFF/PETITIONER; Gerard Ange
DEFENDANT/RESPONDENT: Anthony Temp ler, et. al.
CASE MANAGEMENT STATEMENT CASE UMBE
(Check one): /I UNLIMITEOCASE I I LIMITEDCASE
RG05241337
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 22, 2009 Time: 3:00 pm Depi; 512 Div.: Room:
Address of court (if different from the address above);
24405 Amador Avenue, Hayward, CA 94544
I Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. Liii This statement is submitted by party (name):
b. I ThssatementissubmittedJolntlybyparties1'names: Defendant Gap International, Inc. and
Anthony Templer
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was flied on (date):
b I if \"iy, was filed on (date);
Servco c, j cross-compiainarit.s only)
a. I I All partes mred in the complaint and cross-complaint have been served, or have appeared, or have been dismissed.
b I The fdll.'n pai-t:eo r;-ned in, the complaint or cross-complaint
L.1 have not been served (specify names and explain why not):
1 ] have been sened but have not appeared and have not oeer dismissed. (s.oer!fv names):
ii Liii have haa a deault entered against them (specify names);
c. The fol!c.wing adoition pres may be added (specify names, nature of involvement in case, and the date by which
They mily be serod;.
4. Description of case
a. Type o Case in J/ comp \": cross-conplat ('Describe, u;'c/uding causes of action,t:
IaintifI'asserts causes ofacti n fhr conversion. intentional and negligen: inter lereoce ith prospective
busincs rc1atio: '. :ac .tce iani r TrilL-i' arismg from a dispute \\ er a don;' i;l 1as;ie,
Paso I of 4
4' C'r.'Ca',orr,a CASE MANAGEMENT STATEMENT
.'.i IC. P'v Jr,.'v' 2C.O ;-. 72
.'.'.4 C,' 'i
C,\" C,'C,41\"i r.0
SOW TXJ

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PLAINTIFFIPETITIONER: Gerard Ange
DEFENDANT/RESPONDENT: Anthony Tempter, Ct. al. RG05241 337
4, b. Provide a brief statement of the case, including any damages. (ifpersonal injury damages are sought, specify the injury and
damages cIaimed including medical expenses to date 'indicate source and amounfJ, estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
See Attachment 4b.
I/l (If more space is needed check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury trial I a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a The trial has been set for (date):
b. No trial date has been se This case will be readylo'r trial within 12 months of the date of the filing of the complaint (if
not, explain):
Original trial date has been vacated.
0. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Estimated length of tilal
The party or parties estimate that the trial will take (check one):
a LIII] days (specify number):
b. I I I hours (short causes) (specify): See attachment 4(b)
8. TrIal representation (to be answered for each pally)
The party or parties will be represented at trial I I by tn 2ti(fr1ry or 1 fl tion I by the fcIlowng:
I
Attorney:
Firm:
Address:
Telephone num be
Fax number
E-mail address
Adcitic-ial representation is described in Attachment 8.
9. Preference
[1 This case s entitled to prefere'ce (specify code section):
10. Alternative Dispute Resolution (ADR)
CcUriel has L has cot prcvidec tce ADR ;nfor:rator p>;cfl ientsd ri rule 322 t thu cient and has
reviewed ADR optic-s with the dent.
All onos naoo gooc ic:o1oJ o: DR. APP l t: completed o
ADR /r.u/uatee-(atus, The nianer snJ : ut did nut cttte.
cM- 110 [T1v.
f4
CASE fVIA.NAGEMENT STATEMENT

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PLAINTIFF/PETITIONER: Gerard Ange CASE NUM8eRi
DEFENDANT/RESPONDENT: Anthony Templer, et. al. RG05241 337
10. d. The party or parties are witirig to participate in (check a/I that apply):
1 1 Mediation
1 Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to close 15 days before
arbitration under Cal. Rules of Court, rule 3.822)
Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to remain open until 30 days
before trial; order required under Cal. Rules of Court, rule 3.822)
Binding judicial arbitration
Binding private arbitration
Neutral case evaluation
Other (specify):
I This matter is subject to mandatory judicial arbitration because the amount in controversy does not exceed
the statutory limit
I I Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil
Procedure section 1141.11.
I 1 This case is exempt from judicial arbitration under rule 3811 of the California Rules of Court (specify exemption):
11. Settlement conference
The party or parties are willing to participate in an early settlement conference (specify when):
12. Insurance
I I Insurance carrier, if any, for party filing this statement (name):
Reservationofrights' I I Yes I No
I I Coverage issues will significantly affect resolution of this case (explain):
13. Jurisdiction
Indicate any matters that may affect the courts jurisdiction or processing of this case, and describe the status.
Bankruptcy I I Other (specify):
Status:
14. Related cases, consolIdatIon, and coordination
a L.J There are companion, underlying, or related cases,
Name of case:
Name of court:
Case number.
Status.
,4dd:t oral cases are described in Attachment 14s
b. L_...,] i wo::: o ccnoi-.ate L_i
15. Bifurcation
I I Tne pr3rty or prrtis i :nd to fie a noticc for on order bifurcating sevenno or r,crcnc'ia the fOi.O .'..; :ssues
acUcn s:i' mnirn py, type ofmo;cr, nr,d reasor:si;
16. Other motions
The party c'rn eectto file the fci.nwng motors before tri (specify moving o.orry t'pe fr?nUc' nro ;ss:
CASE MANAGEMENT STATFMENT

CM-lb
PLAINrEF,pEmoNEft Qerard Ang scjJJEa
FB14NT/RSPoNDENT: Anthony Tcmpler, . RG05241337
L
17. Discovery
The pa-ty o partas have completed au duscovery
b. [J The folloMng discovery wit be compkted by the date speoi1ed (desciibo all anlicfpalali discos
Desaictiori
paled (spoc):
Economic Utlijatlon
a Li This Is a ttm,tcd evit case (1 a. the amount dcrnar4ed I
of Civil Procadure sedions 90 through 98 wIfl apply to
b. El its is a miteddu case and a motion to withdraw the case
discovery wilt be Iliad (if checkecl e1an specltcaffy v.iiy economic 1iigabon
shoudnotóppI'ft) this case):
a on isu
Thrparties request that the act a
conferenc (ey):
Maetasd conför
a El of Cout(ffr.c. i/a,
The patty or parties lave metandconferro rIles on au y ri. a724 of the C ..o'nue Rules
Not applicable given status of case.
b. After meeting and conferring as lequired by rule 3.724 of the CatiMnla Rules of
(specl;
21. Totat number of pages 3ttacheu (i!an)2:
completely famLa with this case and wtui be fudy prepared to disaisa the status of duscoveiy and ADI, as well as other issues
taized by this slatument and wi possess the autnonty enter utila ulatons on these uss.ues at the time of the case management
conference, Including the itten authom$ty of tne party where required.
Date:
Maurice R. Mitts. Esquire
CASE MANAGEMENT STATEMENT

ATTACHMENT 4(b)
This case involves a dispute over the transfer of the domain name gapinternational.com to
GAP International. Plaintiff seeks to rescind the iranicr, alleging that Defendant Anthony
Templer (\"Templer\"), dlb/a Atanda Web Presence Services (\"Atanda\") did not have the
authority to transfer the name to GAP International. GAP International, on the other hand, seeks
validation of a transaction in which it was a good faith purchaser in the ordinary course of its
business in an effort to upgrade its marketing efforts.
On October 17, 2003, Mr. Greenawalt of GAP International sent an e-mail offering to
buy the domain name to the four e-mail addresses he found on or linked to the then existing
gapinternational.com website and on November 2, 2003 Mr. Greenawalt checked the public
registry of domain name ownership to ascertain the name of the true owner of the website.
Register Fly listed Atanda as the official registrant for the gapinternational.corn website.' On
November 19, 2003, GAP International acquired two domain names from Atanda,
gapinternational.corn, and an unrelated domain name, gapuniversity.com, for $12,500.
Three weeks later, after GAP International had (1) paid the full consideration for the
transaction, (2) received notice of the transfer of the registration, and (3) shifted its operations to
the new name, Plaintiff Gerard Angé contacted GAP International and claimed that G.A.P. CA
was still the lawful owner of the domain.2 Plaintiff learned of the sale to GAP International on
December 7, 2003 but did not file this lawsuit until November 2005.
After filing this suit, Plaintiff would not cooperate in discovery and repeatedly failed to
produce basic proof on his right as an individual to assert claims on behalf of two corporations,
G.A.P. CA and World Indigenous Network Corporation. After years of pursuing this discovery,
defendants learned that Plaintiff never had an assignment of these corporations' claims.
Moreover, both of these corporations had been suspended from doing business for years and for
several years prior to their suspension, both of these corporations had filed tax returns admitting
that they had no business, no income and no assets. Because of these facts and Plaintiff's refusal
to make discovery and refusal to comply with virtually all of his pretrial obligations, defendant
Gap International, Inc. filed motions in limine to address Plaintiff's failures and misconduct.
Defendant Templer joined in these motions in limine.
At the April 10, 2009 hearing on these motions in limine, four of Defendant's seven
Motions in Lirnine were granted: (a) Defendant's Motion in 10 Preclude Claims and/or
Eridence Related to World Indienous Network Corporation; (b) Defendant's Amended Motion
in l.un,,,r No. 2 t. Preclude Plaintiff's Eridence in Support of Claims by Coiporations Not
Pi''i'u.! . l,.'iiicd to Plain,/f/ a Barred by the Statute of Lunmniun.v: (c) Defendant's Motion
in I.i,iii,u' in Prc lud iih';u c Vot Produced in Discorerv and I'ririaf Dn( imints and
Mr. 1 crjlcrs cii ruin nLric cc HI H Ilr uac him the c rcil\\ md adeunaic inthnrii
ii ,mri'ic I IHtilt. iiir IIJ I. Al' ii lTImi 'ml. 1 lift c\\ ldflC 1mm mmcrHmtc lie ft tumlir 'I (\\l' Inicrrtirmu
or 'HI Ic it 'ft I ide purciuc tIc tim mmcmi muc c LiLflm Ii.
2
i' c rc ktl o net mf ihr dmtrmir cite mit it 'lull cmii. ii ' mr tIme !eJ
Iuriic tIme Clc\\ mlii I It remimmd, \\t._urdu tutrmtutmI Ii ''tic' J)m'l'\\ Imimmi len 'I !Iit' 'ml trier it ft ill lit ed \\t rh
mr lift mmmiImtcrul tern liii H ithme hi'iirmc lftcclmlcrli ml rrIrumm\\Il:cImt himm'.iiri cc' mr timer
hrelmeIIe'trhmehliiI I,rcclnmcrlr. (..\\.i' ( \\ I'tihemO :i'. \\itmimmi;''imiiic'
rH mfft crniuet, Atundm ftmnimrnulcml thm 'ic...t ::::e .1 ( H :
:mt:iI,'i :',, cu'.! H
Imunme .m' 'c limnItem] urnmkr tire rmmhlL\\

Submissions Pursuant to Local Rule 3.35; and (d) Defendant's Motion in Limine to Bar Plaintiff
from Presentinç Any Evidence of Any Damages to Corporations Pursuant to Judicial Estoppel
Doctrine and Caiijrnia Evidence Code 352. Attached is the Court's Order granting these
Motiun', in Li,nine. denying three of Defendant's Motions in Limine, and withdrawing Plaintiff's
outstanding Motions in Limine without prejudice at Plaintiff's request.
Given the current status of the case, Plaintiff will be unable to prove the essential
elements of his claims at trial and thus, the case should be dismissed. Plaintiff is barred from
pursuing any claims on behalf of the corporations because he lacks an assignment and the statute
of limitations provides the Defendants with an affirmative defense against any future claims on
these facts.3 Plaintiff has admitted that he did not personally own the domain name during the
relevant time period.4 Because of Plaintiff's failure to follow the Court rules, Plaintiff is
precluded from introducing any trial exhibits: (1) not already appearing on Plaintiff's Index of
Trial Exhibits; (2) not produced during discovery; and (3) not previously served on Defendants,
including any deposition and discovery responses or audio or visual presentations. Plaintiff is
also precluded from presenting any claim or evidence as to WIN-TV. In addition, Plaintiff
cannot prove damages at trial (which is one of the required elements of each of the claims)
because he is barred from presenting evidence of damages to the corporations.
Defendant, Gap International, Inc. respectfully requests that the Court dismiss this case
and permanently remove it from the trial calendar because, based on the current status of the
case, Plaintiff has no viable claims.
In oddition. ii ' inhpuiel tloit (1 .\\.P. (.\\ was sucpended from domg businecc (in LRiina iI ': a a'. suit from
DeLuii!h 1. In'tjji .\\j'rti ). 20Th and that \\\\ I\\-I1 \\ voi upended on 1)cceinher 1. 2iiIi.. ft tic n pay
iL- ii I: r.iij -till
RLj!uj .t' --ied until at lea.i .-\\ttil 20(t.
Iii au. Plaintiff \\tated u Ic )cduti n in Support of Pkitntti )ppoition to Deftndani' l tin for Sumtnarv
Jicm-nt dated Iuhruai tnt ol Sepkmkr thu Ftiit It thu tttili;iirl name pitttelumlnlrnaic lit
he! Flee! 1 it' Cl tI pali\\ I i..-\\. I', (
\\ordin iii Pliinti11 orpIntion i n t,t runiin Ilk IporaI1oII lidt u'taiit ii 211
Plaiiitiifli!ej ta tetuin br (\\P ( \\ bit time ',tr' 211(iI)-2(104 and I,i\\ return or IV ft ar
2004. I 11C11 1 lIe ta\\ RI UI U- :hon /Ct line nile mid e\\eIoe and e-ItIaln a ni nc elaiini inn diat
ic'im m1m miilt-r!it\\rL-tIilIt-.iim- -nj lmt!liClItjtim:ni1'\\\\ll;lII\\ :-t_-tjjum.mi-
Ilki liii -tt '. i-- .......I in
(ILlIIiI.L Ilidi II IIIC [k I I

ATTACHMENT 8
Additional Counsel:
Jeffrey S. \\Vruble (#94734) and Mia S. Blackler (#188112)
BUCHALTER NEMER PC
333 Market Street, 25 Floor
San Francisco, CA 94105
(415)227-0900 (t)
(415) 227-0770 (f)
mblackler@ buchalter.com

MIlTS MILAVEC, LLC
Maurice R. Mitts
2 Carolyn M. Plump (#156777)
Two Logan Square
3 Eighteenth & Arch Streets, 12th Floor
Philadelphia, PA 19103
4 Telephone: (215) 569-1800
Facsimile: (215) 569-1822
5 rnrnitts @ mittslaw.com
6 BUCHALTER NEMER PC
Jeffrey S. Wruble (#94734)
7 Mia S. Blackler (#188112)
333 Market Street, 25th Floor
8 San Francisco, CA 94 105-2126
Telephone: (415) 227-0900
9 Facsimile: (415) 227-0770
mblackler@buchalter.com
10
Attorneys for Defendant
11 GAP INTERNATIONAL, INC.
12 SUPERIOR COURT OF THE STATE OF CALIFORNIA
13 COUNTY OF ALAMEDA - UNLIMITED JURISDICTION
14 GERARD ANGE,
II Case No. RG0524 1337
15 Plaintiff,
[peett1ORDER RE MOTIONS IN LIMINE
16 vs.
Hearing: April 10, 2009
17 ANTHONY TEMPLER, e Time: 1:30pm
Dept.: 512
18 Defendants. Judge: Honorable John M. True, III
Trial De: April 20, 2009 (now vacated)
19
20
21 The respective Motions i Liinine of Plaintiff Gerard Angi ('Plaintiff\") and Defendant
22 AP International, Inc. (\"(i came on for hcrin' \\prii 10 2fl(). t 1:30
23 p.m. before DepirtIT]dnt 512 of the above-entitled Court, the Honorable ,Juhn \\i. Iruc ill
24 presiding. (t .lia L. Woods and Gerard Angé appeared for Plaintiff. Maurice R. Mitts and Mia
25 S. Blackler ppcarJ 11. GAP International.
26 Hd\\ in re Lvd the parties' rnotiuln.c in liinin'. and the responses Luld joinder thcrein.
. i
T
1
LPRt )1')si;I )RVi.i( 1<1. .\\I() i\\i1\\.L - .\\S \\( ). i(U05241337

IS HEREBY ORDERED as follows:
2 1. As to Defendant GAP International's Motions in Limine:
Motion in Limine No. 1 (To Preclude Claims and/or Evidence Related to
4 World Indigenous Network) GRANTED;
5 Amended Motion in Liinine No. 2 (To Preclude Plaintiff's Evidence of an
6 Assignment of Claims) GRANTED;
7 Motion in Limine No. 4 (To Estop Plaintiff from Presenting Evidence or
8 Requesting Relief Based On Federal Claims) DENIED for the purpose of leaving to trial any
9 issue of an actual claim for relief under Federal law;
10 Motion in Limine No. 5 (To Preclude Evidence Not Produced In Discovery
11 and Pretrial Documents and Submissions Pursuant to Local Rule 3.35) GRANTED;
12 Motion in Limine No. 6 (To Exclude Plaintiff's Altered Website Exhibits
13 and Misleading Demonstrative Evidence Timeline Pursuant to California Evidence Code Sections
14 350, 352 and 1401) DENIED for the purpose of leaving to trial any appropriate objections;
15 f Motion in Limine No. 7 (To Preclude Plaintiff's Introduction of Irrelevant
16 and Improper Expert Testimony Pursuant to California Evidence Code Sections 350, 352, 801
17 and 805) DENIED for the purpose of leaving to trial any appropriate objections; and
18 g. Motion in Limine No. 8 (To Bar Plaintiff from Presenting any Evidence of
19 any Damages to Corporations Pursuant to J.idiiol Fctppel Doctrine and Californiu
20 Code Section 352) GRANTED.
21 I-
II
23 II
24
25
26
28
VI
[PROP S1.Dj ORDER Ri-. \\1Ot!U 1\\ 11.\\1I\\E - CASI-. No. RGO523JL37

1 2. As to Plaintiff Gerard Ange's Motions in Limine:
2 At Plaintiffs request, the hearing of Plaintiffs previously undetermined Motions in
Limine (Whether To Exclude Argument or Reference To G.AP. International's or WinTV's
4 Suspensions, and Whether To Exclude Defense Exhibit D58), are hereby are hereby withdrawn
5 without prejudice to be taken up again when a new trial date is set.
6
DATED: , 2009
7 HON. JOHN M. TRUE 111
RIDGE OF THE ALAMEDA COUNTY
8 SUPERIOR COURT
9
10
11 Approved as to Form and Content:
12
13
DATED: , 2009
14 GERARD ANGE
Plaintiff in Propria Persona
15
16
17 DATED: 2009
I FR dba ATANDA WEB
18 PR CE SERVICES
Dedant in Propria Pcrsoaa
19
20
21
22
23
24
25
26
2
JCM'E? NFVk
[PROPOSEL)} ORDER RE MOTIONS Th UM INE - C ASE NO. RG0524133

CLERK'S CERTIFICATE OF MAILING
CASE NO: RGO5-241337
CASE NAME.....igc V. Templer
I ccrtifv that I am not a party to this action and this correspondence was mailed first class,
prcpaid postage, in a sealed en cLipe to the parties at the addresses shown below. The
mailing and this certification occurred at the place and on the date shown below:
Gerard Ange' Buchalter Nemer PC
3879 Magnolia Dr. Attn: Mia Blackler
Palo Alto, CA 94306 333 Market St., #2Sth Fl
San Francisco, CA 94105
Mitts Milavee, LLC
Attn: Maurice Mitts
2 Logan Square
18th
& Arch Streets, l2\" fi
Philadelphia, PA 19103
Place of mailing: Hayward, CA
Date of mailing: May 7, 2009
By: , Deputy Clerk
Stacy Oxsen

PROOF OF SERVICE
I am employed in the County of San Francisco. State of California. I am over the age of
18 and not a party to the within action. Ny business address is at BUCHALTER NEMER, A
Professional Corporation, 333 Market Street, 25th Floor, San Francisco, California 94105-2 126.
On the date set forth below, I served the foregoing document described as:
CASE MANAGEMENT STATEMENT
on all other parties and/or their attorney(s) of record to this action by placing a true copy thereof
in a sealed envelope as follows:
In Pro Sr In Pro Sr
Mr. Gerard Ange Anthony Templer
3879 Magnolia Drive Atanda Web Presence Services
Palo Alto, CA 94306 939 61 Street, Suite 13
wi ntv(sbcgl obal net Oakland, CA 94608-130 1
Anthon\\@atanda.corn
BY MAIL I am readily familiar with the business' practice for collection and processing
of correspondence for mailing with the United States Postal Service. The address(es) shown
above is(are) the same as shown on the envelope. The envelope was placed for deposit in the
United States Postal Service at Buchalter Nemer in San Francisco, California on June 5, 2009.
The envelope was sealed and placed for collection and mailing with first-class prepaid postage on
this date following ordinary business practices.
BY EMAIL. On June 5, 2009, 1 caused the above-referenced document(s) to be sent in
electronic PDF format as an attachment to an email addressed to the person(s) on whom such
document(s) is/are to be served at the email address(es) shown above, as last given by that
person(s) or as obtained from an internet website(s) relating to such person(s), and I did not
receive an email response upon sending such email indicating that such email was not delivered.
I declare under penalty of pe!jury under the 1n' f the State of California that the
foregoing is true and correct to the best of my knowltdge, Executed on June 5, 2009, at San
Francisco. California.
Dodie Fontano
I, .
- -r
(Siunature)
IR()()l Ol sl.R\\ 1(1. - (\\Sl .\\O, RGO24L37