PAO Group Inc (PAOG): LAWSUIT DOCUMENTS in my defamation suit...

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Thursday, 11/08/2007 2:31:16 AM

Thursday, November 08, 2007 2:31:16 AM

LAWSUIT DOCUMENTS in my defamation suit against IMNM. The judge ordered the company to obtain new legal counsel within thirty (30) days. Prior counsel admitted he represented Paul Taylor and was NOT PAID for his services.

This is the Complaint I filed against IMNM for defamation
http://clerkofcourt.info/IMNM/2006-11-30.Complaint_against_IMNM.pdf

This is a letter from a guy named Tom Bibiyan that claims IMNM didn't defame me -- he did. Problem is, how did he know my son's name and the name of Paul Taylor's son (Zach). Worse, he says he did it for the hip hop company -- but this was still CCDX! I love this guy!
http://clerkofcourt.info/IMNM/2007-09-10.Bibiyan_Letter.pdf

Here's my motion for leave to do some more discovery
http://clerkofcourt.info/IMNM/2007-09-25.Calderon_Motion_for_Discovery.pdf

Then IMNM's attorney moved to withdraw. He said Paul Taylor sold the company without telling him.
http://clerkofcourt.info/IMNM/2007-10-01.Motion_to_Withdraw.pdf

Based on the name change, I asked the Court to amend the caption. The judge hasn't ruled yet:
http://clerkofcourt.info/IMNM/2007-10-09.Motion_Amend_Name.pdf

The judge denied my motion for more discovey to investigate Tom Bibiyan. She said it was an improper ex parte contact:
http://clerkofcourt.info/IMNM/2007-10-11.Order_Denying_Discovery.pdf

The judge denied the motion to withdraw because she reminded counsel that the defendant isn't Paul Taylor, but the company. She told counsel to serve the company:
http://clerkofcourt.info/IMNM/2007-10-11.Order_Denying_Motion_Withdraw.pdf

Counsel complied and provided the new contact information for Mr. Cotton. He again reminded the Court that Paul Taylor was in control when he was hired in late 2006 and that he transferred control without advising counsel.
http://clerkofcourt.info/IMNM/2007-10-16.Amended_Withdrawal.pdf

Paul Taylor answers discovery as "authorized agent" for the company. Paul states he is a preferred and common shareholder. Also pay careful attention to his notarized affidavit:
http://clerkofcourt.info/IMNM/2007-10-17.Responses_to_Interrogatories.pdf

Here is an appeal I filed asking the district judge to allow investigation into Tom Bibiyan:
http://clerkofcourt.info/IMNM/2007-10-18.Objections.pdf

The judge orders IMNM to obtain new counsel:
http://clerkofcourt.info/IMNM/2007-11-01.Order_Directing_IMNM_to_Obtain_Counsel.pdf

I file a motion asking the Court to compel the company to provide answers signed by an agent of the company, not Paul Taylor since he said he "resigned" and is now just a preferred shareholder.
http://clerkofcourt.info/IMNM/2007-11.06.Discovery_Compell.pdf