Replies to post #31981 on Neuralbase Ai Ltd (VIRAD)

[E R N I E]

Stephanie Johnson Declaration in Support of Preliminary Injunction

William K. Vogeler SBN 147445
Gruenbeck & Vogeler
Six Venture, Suite 270
Irvine, Calif. 92618
Phone: [phone]
Fax: [phone]


Attorneys for Plaintiffs
HERGOTT PRODUCTIONS, INC.
MUFFIN CLUB ENTERTAINMENT, INC.
And JAMES HERGOTT


UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA

HERGOTT PRODUCTIONS, INC., a California corporation; MUFFIN CLUB
ENTERTAINMENT, INC., a California corporation; and JAMES HERGOTT, an
individual,

Plaintiffs,
vs.
IMPERIA ENTERTAINMENT, INC.; a Nevada corporation; IMPERIA
INTERNATIONAL DISTRIBUTION, INC., a Nevada corporation; MULLER MEDIA,
INC., a Nevada corporation; NEVER SUBMIT, LLC., a Nevada limited
liability company; KENNETH EADE, an individual; and DOES 1 through
10,

Defendants. )
)
)
)
)
)
)
)
)
)
)
))))))))))))) Case No.: SACV07-553 DOC (MLGx)




DECLARATION OF STEPHANIE JOHNSON IN SUPPORT OF REPLY TO OPPOSITION TO
MOTION FOR PRELIMINARY INJUNCTION


DATE: June 12, 2007
TIME: 10:30 a.m.
PLACE: Dept. 9D


I, Stephanie Johnson, declare:
1. I am an adult and not a party in the above-captioned matter. I
know the facts set forth in this declaration are true of my own
knowledge, except those facts stated upon information and belief, and
I believe those facts to be true. If called upon, I would testify
competently to these facts.
2. I am a former employee of Imperia Entertainment, Inc. and a close
friend of James Hergott. I have known Mr. Hergott personally for about
three years.
3. I have been present on many occasions as Mr. Hergott worked on his
script, "Never Submit." I read the script for the first time in March
2006, before he offered it as a movie project to Imperia.
4. As a public relations representative for Imperia in 2006, I built
professional relationships with various mixed martial arts
organizations, including editors of mmaweekly.com, masfighting.com,
sherdog.com and others to promote the project. I also developed a
myspace profile and a gmail account to promote the project. I also
scheduled auditions and press interviews for Mr. Hergott throughout
the country.
5. In all these communications, I represented on behalf of Imperia
that Mr. Hergott was the author of the script and director of the
movie. But on or about March 21, 2007, I learned that Mr. Hergott had
been removed from the project.
6. So on March 23, 2007, I resigned from my position with Imperia.
7. I declare under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing is
true and correct.
Dated: June ___, 2007