141114-yelp mcmillan-filed decl of julian mcmillan in supp of defs' repl

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  • 8/10/2019 141114-Yelp McMillan-Filed Decl of Julian McMillan in Supp of Defs' Repl...

    1/14

    Scott

    A.

    McMillmt,

    CBN

    212506

    Michelle D.

    Volk,

    CBN

    217151

    The McMillan I.;tw

    I.

    irm,

    APC

    4670

    Nebo

    Drive,

    Suite

    200

    La

    Mesa,

    CA

    91941-5230

    Tel

    (619)

    464-1500

    x

    14

    //

    Fax

    (206)

    600-5095

    ematl: scott(itlmcmillanlaw.us

    Attorneys

    for

    Defendants

    McMillan Law

    Group,

    Inc.

    And Juhan

    McMillan

    8

    Sl

    JPERIOR COUR f OF CALIFORNIA, COUNTY OF SAN

    DIEGO

    10

    11

    12

    13

    14

    15

    YELP,

    INC.,

    a Delaware

    Corporation

    Plaintiff,

    V.

    MCMILLAN LAW

    GROUP, INC., a

    California

    Corporation,

    and

    JULIAN

    MCMILLAN,

    an indivtdual

    De

    fendants,

    San

    Diego

    Superior

    Court Case

    No:

    37-2014-00004953-CU-BT-CTL

    DECLARATION

    OF JULIAN

    MCMILI.AN

    IN SUPPORT OF

    DEFENDANTS'EPLY

    BRIEF

    IN

    CONNEC'I

    ION

    WITH

    DFE NDANS'OION

    IJNDER C.C.P.

    (425.16

    20

    Hearing

    Date:

    November

    21,

    2014

    Hearing

    Time:

    8:30 a.m.

    Courtroom:

    C-69

    Honorable

    Joan

    M.

    Lewis,

    Judge.

    Complaint Filed:

    August

    20,

    2013

    Trial Date: None set

    I,

    Julian McMillan,

    declare

    as

    follows:

    26

    1.

    I am

    an

    attorney

    duly

    licensed

    to

    practice

    law before all courts of

    the

    State

    of

    California.

    My

    law

    ftrm,

    The McMillan Law

    Group

    and I are the

    Defendants in

    this

    action.

    Except

    as

    to those

    matters which I state on information

    28

  • 8/10/2019 141114-Yelp McMillan-Filed Decl of Julian McMillan in Supp of Defs' Repl...

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    and belief,

    and as

    to those matters

    I believe them to

    be

    true,

    the

    lol

    lowing

    lacts

    are within

    my

    personal knowledge

    and,

    if called as

    a

    witness herein, I

    can and

    will

    competently

    testify

    thereto.

    2. I

    have

    personally

    reviewed the

    opposition

    to the

    anti-SLAPP

    Motion

    currently

    at

    issue

    in

    this

    case.

    I have

    also

    reviewed

    the

    Declarations

    of Ian

    Macbean

    and

    Vince

    Solitto

    and

    associated

    exhibits.

    g

    3. Prior to the

    filing

    of the instant

    litigation,

    I never read

    the

    Yelp

    "Terms

    9

    of

    Service".

    Similarly,

    I

    was

    not aware that those

    "Terms

    and

    Conditions"

    ever

    10

    changed.

    11

    12

    ~

    4. Exhibit F to

    the

    Reply

    Brief

    fairly

    and

    accurately

    depicts

    my

    personal

    13

    Yelp

    Profile as I viewed

    it

    on the internet

    at:

    http:

    //www.velp.corn/user

    details?userid=EFSctHg-Nj16qtds33fMXw

    15

    16

    17

    Ig

    19

    20

    21

    22

    23

    24

    25

    5.

    I wrote

    what

    would

    be

    my

    final

    Yelp

    review

    on

    May

    5,

    2013.

    Having

    already

    been in the smail claims

    court

    dispute

    with

    Yelp.

    This

    review was of

    Solare

    Ristorante,

    which by this point

    in

    time

    had

    essentially

    become

    "My

    I.ocal"

    here in Point

    Lorna.

    I

    have

    marked

    that

    as Review

    1

    of

    Exhibit F:

    I had

    been

    working

    long

    days

    and

    eating

    very

    sporadically

    for the duration

    of

    it.

    In

    my

    experience,

    most Italian restaurants

    in this

    part

    of the world

    seem

    to think,

    for

    whatever

    reason, that a steak

    needs

    to

    be

    covered in cooked tomatoes.

    I believe it

    is refened

    to

    as

    "Sinatra

    Style".

    I

    can't

    eat

    that

    as

    it

    gives

    me

    very

    severe

    heartburn.

    The waiter

    listened

    to me

    and

    the

    restaurant

    obliged.

    I

    gave

    them

    5

    stars,

    and

    wrote

    the

    following

    review:

    "So...

    Tonight

    I went in with a

    colleague,

    declined the

    menu and

    just

    told

    the server

    I wanted

    their best cut of beef.

    I-Ie

    left,

    but returned to tell me

    that

    they

    were

    updating

    the menu on

    Tuesday

    and there

    was

    a

    new

    "Tomahawk

    Ribeye".

    I

    was born in

    Canada,

    have

    been

    to

    New

    Zealand,

    Australia,

    Argentina,

    and

    dined

    in some

    of

    the finest restaurants

    of

    London,

    i

    2O/V-OOOOVP53

    DECI.

    ARATION

    OF.IULIAN

    MCiviiLLAN

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    Paris and

    Tokyo.

    This was

    by

    a

    country

    mile

    the

    best steak this country:

    boy

    made

    good

    has

    ever

    has.

    The 24oz

    bone

    in

    cut

    was

    only

    lacking

    in that it

    was not

    a 48

    oz

    cut.

    Glutton

    that

    I

    am,

    when

    I

    tmd

    a

    good

    thing,

    all I want

    is more.

    I am so

    happy

    that there

    is finally a

    non"

    steakhouse"

    where

    wy

    wife can eat

    that

    I

    can find a fantastic

    steak.

    Salud to

    Solare,

    finally

    an Italian restaurant

    truly

    in the Sicillian

    tradition."

    91

    6.

    On October

    30,

    2012

    I

    wrote

    my

    next

    Yelp

    review,

    of

    Solare

    Ristorante,

    10

    which I marked

    as

    Review

    2 of Exhibit F.

    Solare Ristorante

    had

    just

    changed

    ownership and the

    new

    owner was

    very

    interested in what he could do to attract

    more

    locals.

    At that

    point

    they

    had not developed

    much

    of a

    child's

    menu. He

    13

    offered

    to make whatever I

    wanted

    for

    my

    then

    18 month

    old. I

    asked for

    grilled

    chicken,

    asparagus

    and butternut

    squash.

    They

    delivered. To this

    day,

    that

    dish

    appears

    on

    the

    child's

    menu,

    simply

    labled

    "Sam's

    Choice."

    I

    gave

    them five

    stars and wrote the following

    review:

    17

    21

    22

    23

    "Sunday

    night

    I

    took

    the

    neighbors

    and my

    18

    month

    old son

    to

    Solare. The food and

    wine

    were

    both fantastic. The

    big

    sell

    for me

    was

    that

    for

    my

    son, they

    prepared

    a

    child's

    meal

    composed

    of

    grilled

    chicken,

    asparagus

    and

    butternut

    squash.

    As a

    parent,

    I

    will

    always

    choose a restaurant

    where

    my

    child is

    not

    reduced

    to

    a

    grilled

    cheese

    sandwich, chicken

    fingers

    and

    fries over

    any

    other. Sam

    loved

    all of

    it. Kudos to the

    chef

    and

    staff for their

    efforts."

    25

    7. I

    wrote

    a

    Yelp

    review on

    April

    9,

    2012 of

    Solare

    Ristorante

    Review 3 of

    Exhibit K:. As the

    review

    states,

    my

    wife and I had been

    there

    previously

    a

    number of

    years

    before and

    never went

    back.

    I

    was

    sort

    of

    dragged

    back in

    sometime in

    April

    of

    2012,

    I

    gave

    it five stars and wrote the following review:

    "My

    wife

    and I had

    been

    to

    this restaurant

    in

    2008 and found it

    very

    2074-00004953

    DECLARATION OF

    JULIAN

    MCMILLAN

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    expensive

    and felt

    that

    the

    stafl'were

    overwhelmed with a

    very

    small

    number

    of

    customers.

    A

    colleague of mine

    though

    had

    insisted last

    summer

    that

    it

    was

    fantastic.

    So,

    we tried

    it

    again

    and

    were

    very

    glad

    we

    did.

    The

    pricing

    had been

    adjusted

    downward,

    the

    food

    quality

    and

    presentation

    had

    been

    adjusted upward

    and it was

    a

    very

    positive

    experience all round. I would

    highly

    recommend a visit for

    anyone

    thinking of

    trying

    it."

    8

    8. I wrote a

    Yelp

    Review on

    July 25,

    2012 of Sachdev

    Law,

    Review 4l of

    9

    Exhibit P:.This

    was

    a

    child

    custody

    matter

    that I

    am

    happy

    to discuss in camera,

    10

    i

    but otherwise will not

    go

    into too

    much

    detail. Suffice

    it

    to

    say

    that

    I

    was

    very

    happy

    with the

    service

    my

    family

    received. I

    gave

    Sachdev

    Law five stars

    and

    wrote the

    following

    review:

    13

    "I

    went

    to no

    less

    than

    10 attorneys

    before

    visiting

    Sachdev Law. No

    one would take

    my

    matter

    for

    less than

    $

    75,000.00. Sachdev I.aw

    came

    in at a little less than half of

    that,

    dealt with the matter

    efficaciously and

    I

    got

    a

    check

    for

    the

    remainder

    of

    the

    fees.

    I

    don'

    know

    if

    anyone

    else

    on

    the

    planet has ever gotten change

    from and

    attorney. This is

    certainly

    the

    first

    time

    I

    ever

    have.

    Where

    most

    attorneys told me

    I

    had a

    very

    difficult case

    and chances

    of success

    were

    unlikely,

    Puja

    seemed

    to

    know

    off the

    top

    of

    her

    head

    how to

    handle

    the

    matter,

    and

    then

    handled it. If

    I

    could

    give

    7 stars I

    would.

    Don't

    waste

    your

    time

    with

    other

    family

    law

    attorneys.

    Hire

    youth,

    energy

    vigor

    and knowledgef

    I I

    fhanks Pujai

    I I

    I"

    9.

    I

    wrote a

    Yelp

    Review on

    April

    19,

    2012

    Review

    5 of Exhibit F. This

    was a review

    of

    the telecommunications

    company

    we

    used

    for the

    office

    phones

    and internet.

    They

    were

    awful.

    The

    system

    was a

    very

    unreliable

    VOIP,

    and the

    download

    speeds

    were

    slower

    than the

    wi-fi

    at

    the local

    Starbucks. We

    had issues

    with

    people

    emailing

    to

    say

    they

    had

    tried

    to

    call,

    but

    only

    ever

    got

    either

    a

    busy

    signal

    or

    put

    through

    to

    a

    call

    center in

    India.

    Also,

    the

    system

    just

    randomly shut

    2074-00004953

    Dl:CLARATION

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    down

    for hours

    at a

    time. I

    gave

    them

    one star and

    wrote

    the following review:

    "Very

    disappointed

    with their

    service.

    The

    phones

    are in and out

    iintermittentiy

    and

    callers are told the

    numbers have

    been

    disconnected.

    Running

    a

    small

    business

    is

    tough

    enough

    without

    having

    to

    deal

    with

    these

    sort of complications.

    I

    would

    discourage

    anyone

    from

    signing

    on with

    them. Customer

    service is

    through

    a

    website.

    How

    ironic that

    your

    internet is

    down and

    you

    can't

    log

    in

    to

    complain."

    12

    13

    14

    I

    O. I wrote

    a

    Yelp

    review on

    April

    9,

    2012

    of

    Gabardine

    Restaurant

    in

    Point

    Lorna

    Review

    6

    of

    Exhibit

    K:.

    We

    actually went there

    by

    mistake as there

    used to be

    a

    bistro owned

    by

    a

    lovely couple

    from New

    Zealand

    and

    they

    had

    a

    great

    lamb

    burger.

    I

    gave

    them three stars

    and wrote the

    following

    review

    of

    Gabardine

    Restaurant:

    "My

    wife and

    I

    did not

    know what to

    expect

    in this

    new

    restaurant

    in

    Point

    Lorna.

    We

    went their

    for dinner on

    a

    Sunday night.

    It

    was

    lively

    and

    had

    an

    eclectic

    decor. We now see it

    more

    as a

    seafood

    tapas

    bar

    than

    a

    dinner restaurant.

    It

    wasn't

    what we hoped for, but

    anyone

    looking

    for this

    sort

    ofplace

    I am sure

    will

    be

    pleased."

    21

    25

    11.

    On

    April

    6,

    2012 I wrote

    my

    first

    Yelp

    Review.

    1VIy

    wife

    and

    I are

    both

    self

    employed

    and

    my

    wife

    travels a

    great

    deal

    for work.

    It

    was

    prudent

    to have an

    estate

    plan.

    It

    is not

    an area of

    law that

    I have a

    great

    deal

    of expertise

    in.

    As

    well,

    I had

    seen estate

    planning

    lawyers

    that

    charged

    some

    very high

    fees.

    Ashley

    was

    great

    and

    very

    reasonable.

    Ashley

    deserved

    S

    stars

    in

    my

    mind.

    I

    wrote

    the

    following

    review of

    Teague

    Law,

    which I have marked

    as

    Review 7 of

    Exhibit

    K:

    "My

    wife and

    I had our

    first

    child

    last

    year.

    T'his

    prompted

    us

    to

    start

    thinking

    about

    Estate

    Planning.

    I

    asked some friends, and

    Ms.

    Teague

    had

    received some of the most

    glowing

    recommendations

    from some

    of

    the

    most

    critical

    people

    I have ever

    known. We

    met

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    JIlLIAN

    MCMILLAN

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    10

    12

    with

    Ashley

    and she was

    very quickly

    able to provide a

    course

    moving

    forward

    and

    steer us

    through

    it.

    It is

    not often

    you

    meet

    an

    attorney

    who

    can so easily

    translate the

    legalese

    into comprehensible

    English.

    Not

    only

    did we

    get

    what we

    need,

    but I

    understand it

    as

    well. Ms.

    Teague

    has

    also been

    fantastically

    responsive to our follow

    up

    questions.

    I

    never wait

    more than a

    day

    for

    a

    return call or

    email.

    To call

    this

    level of

    responsiveness

    rare in

    attorneys

    in

    my

    experience is

    selling

    it short.

    Most

    of

    thein think that

    they

    are

    too

    important

    to talk to

    you

    or

    perpetually

    on

    vacation. Ms.

    Teague

    is

    first rate.

    My

    only

    criticism is

    that

    I wish she

    were

    versed

    in other

    areas

    of

    law so

    that we

    could

    get

    the

    same

    level

    of service in the

    other

    areas

    we

    require

    advice.

    That

    said,

    she

    has

    always

    been

    able

    to

    provide

    quality

    referrals

    to us.

    Ms.

    Teague,

    carry

    on

    my

    lady,

    carry

    on...

    16

    17

    12.

    On

    February 1,2013

    I wrote a review of

    Eddie

    V's

    Prime

    Seafood.

    My

    ~

    neighbors had taken me out

    for

    my

    birthday.

    I

    wrote the following

    review

    of

    Eddie

    V's

    Prime Seafood, which

    I

    have

    marked

    as

    Review 8 of

    Exhibit E:

    20

    "Had

    a fantastic

    dinner

    experience

    there on

    Wednesday night

    this

    week.

    Lobster

    tacos

    followed

    by

    the Rib

    Eye.

    All was

    way

    above

    par

    and the

    Jazz

    night

    was

    a lot

    of

    fun.

    Great

    views of La Jolla

    Shores from the

    patio.

    I

    would

    recommend

    this

    place

    to

    anyone."

    13. In

    December

    of

    2012,

    I had taken

    my

    family

    to

    Maui. We

    found

    a

    fish

    taco

    shop

    in

    Kihei

    for

    lunch

    one day.

    I

    ate

    at

    this

    restaurant.

    I

    met

    the

    owner. He

    named the

    place

    after

    his

    cat

    "Coconut".

    I

    gave

    the

    restaurant

    5

    stars and wrote

    the following review which is marked as

    Review

    9 of

    Exhibit

    F:

    "Not

    only

    was

    this

    worth

    the

    drive from

    l

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    14. On

    the same

    triip

    to

    Maui

    referenced

    above

    . We

    stayed

    in

    Kapalua.

    One

    night

    we

    decided to

    have

    dinner at the

    hotel's

    poolside

    restaurant

    named

    the

    Banyan

    Tree where we could watch

    the sunset. Curiously,

    there

    is no

    Banyan

    tree

    anywhere

    near the restaurant. I have marked

    that review as

    Review

    IO

    of

    Exhibit lY. The sunset

    was

    the

    only good part

    of the experience.

    I

    think

    my

    review was

    pretty

    accurate. I

    gave

    them one

    star,

    and

    wrote the following

    review:

    10

    "Not

    impressed. The

    location

    of

    the

    restaurant

    is

    wonderful. However,

    the

    service

    and

    food

    was

    really

    a

    mixed

    bag.

    We have a 19 month

    old and the

    options

    on the

    children's

    menu

    were

    pretty

    depressing.

    The

    staff

    seemed

    annoyed

    at

    having

    to

    be

    there. When

    you

    stay

    at

    a

    remote

    resort such as the

    Ritz

    Carlton

    in

    Kapalua,

    your

    choices

    for

    dining

    out

    are limited.

    The

    service and the food at this

    restaurant reflect

    that

    they

    understand

    they

    have

    a

    captive

    audience."

    15

    15. I

    wrote

    my

    next

    Yelp

    review

    on

    August 15,

    2012

    Review

    I I of

    Exhibit

    F.

    My

    wife

    was

    out

    of

    town

    and

    I

    was

    missing

    work to take our

    child

    to a

    7

    routine check-up. As

    the

    review indicates, he

    was

    about

    1 5

    months

    old

    at

    the

    Ig

    time. We

    had

    a

    9:30

    AM

    appointment

    (first

    one

    of

    the

    day). We

    were

    left

    in

    the

    exam room for over an hour.

    My

    child

    had been

    stripped

    down to

    his

    diaper

    for

    19

    the duration

    of that time

    and had

    grown

    more

    than a

    little

    impatient

    with the

    20

    whole

    experience.

    I

    gave

    them one

    star,

    never

    went

    back

    again,

    and

    wrote

    the

    following review:

    22

    "I

    took

    our 15 month

    old in for a 9:45

    Appointment.

    We

    arrived and

    checked

    in

    at

    9:30.

    At

    10:00

    we were

    escorted

    to

    an

    exam room

    where we sat unattended

    for

    just

    over an hour.

    Needless

    to

    say,

    a

    15

    month old

    gets pretty

    bored

    and

    frustrated

    in a 6

    by

    8 foot room.

    When

    the Dr.

    Finally

    came

    in,

    she

    spent

    all

    of

    3

    minutes with us and

    then said the nurse would

    be

    right

    in

    to

    give

    him

    his

    immunization

    shots. That took

    another

    30

    minutes. I cannot think

    of

    any

    other

    professional

    service

    where the

    client

    is expected

    to wait for an hour

    2014-00004953

    DECLARATION OF

    JULIAN

    MCMILLAN

  • 8/10/2019 141114-Yelp McMillan-Filed Decl of Julian McMillan in Supp of Defs' Repl...

    8/14

    beyond

    an

    appoinlment

    time.

    My

    child was

    completely

    traumatixed.

    I le is

    not

    old

    enough

    to understand what is

    going

    on,

    and

    to force

    him to wait

    around

    like

    this

    and

    then

    be

    conlronted

    with

    two

    total

    strangers

    who

    are

    poking

    and

    prodding

    at

    him,

    and

    then

    the shots. It

    was

    nothing

    short of a

    complete

    traumatic

    experience for him.

    It

    threw off

    his

    whole

    day,

    he

    wouldn't

    nap,

    would

    not

    eat.

    When I confronted the

    Dr. about how late she

    was,

    she

    simply

    commented

    that

    they

    were

    unexpectedly busy.

    I

    told

    her it is

    always

    that

    way

    in their

    office.

    1

    pointed

    out

    that

    everyone

    I saw in the

    waiting

    room had an

    appointment.

    Given that

    they

    are booked

    months

    in

    advance, there

    is no

    way

    they

    did

    not

    know how

    many

    patients were

    booked.

    There

    were

    no

    waiting

    children

    or

    parents

    in the

    "sick child"

    waiting

    room.

    16

    Why

    do

    Dr.'s

    get

    away

    with this? As well,

    this

    being

    a

    children's

    medical

    office, surely

    they

    would understand

    how

    difficult it is to

    keep

    a child calm

    for

    that

    duration

    of time. For

    my

    son,

    it

    was

    just

    a

    very

    traumatic

    experience.

    If at 9:45

    you

    are

    already

    running

    an hour late on

    your

    daily

    calendar,

    you have

    serious

    time

    management

    issues.

    If

    I

    had

    been

    an

    hour

    late,

    they

    would

    have

    canceled

    the

    appointment

    and

    billed me

    for it.

    What

    is

    my

    recourse on

    them?

    I have

    only

    this

    and

    other forums

    in

    which I can

    express

    my

    frustration and

    warn others. We are

    actively

    seeking

    a

    new Dr.

    While I

    understand

    that we

    will

    more than

    likely

    encounter something

    similar,

    I cannot believe

    they

    will aII be

    this

    bad."

    16.

    The

    above

    reviews

    are

    the only reviews

    I

    have authored

    on

    Yelp, or

    otherwise

    caused

    to

    be

    authored. The reviews

    are

    sincere statements

    based

    on

    my

    own

    experience which I

    posted

    to

    provide

    others a

    report

    of

    my

    personal

    27

    experience,

    17.

    I

    did

    not

    instruct

    any

    other

    person

    to

    give

    me

    or

    McMillan

    I.aw

    Group

    reviews.

    l

    2O14-OOOO495S

    DI:nARATIobl

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    IUI.IAN

    ivlCMILr

    AN

  • 8/10/2019 141114-Yelp McMillan-Filed Decl of Julian McMillan in Supp of Defs' Repl...

    9/14

    I

    2

    3

    l 8. I note

    that reviews

    that

    were

    filed

    by

    Isabella I

    ung suggests

    that

    she

    received

    legal

    services from me.

    By

    virtue

    ol'he

    California

    Rules of Professional

    Conduct for

    Attorneys,

    and the

    California

    Business

    and Professions Code

    Section

    6068(e)(1),

    I

    am not able

    to

    discuss

    any

    legal

    services

    that Isabella

    Lung,

    received,

    if

    any.

    7

    81

    9

    19.

    However, in

    her

    capacity

    as

    a

    Firm

    employee,

    I never instructed,

    advised or asked her to

    write

    a

    yelp

    review of the

    McMillan Law

    Group

    or

    mysel

    f,

    Julian McMil

    lan.

    10

    12

    13

    14

    20.

    I

    note

    that

    the reviews that were

    posted

    to

    yelp.corn

    by

    Andrew

    Boylan

    suggest

    that he

    received

    legal

    services

    from

    me.

    By

    virtue

    of

    the

    California

    Rules

    of

    Professional

    Conduct for

    Attorneys,

    and the

    California

    Business

    and

    Professions Code

    Section

    6068(e)(1),

    I

    am not able to discuss

    any

    legal

    services

    that

    Andrew

    Boylan,

    received,

    if

    any.

    15

    17

    18

    21.

    However,

    in his

    capacity

    as

    a

    Firm

    employee,

    I never instructed,

    advised or asked him to

    write

    a

    yelp

    review of

    the

    McMillan

    I.aw

    Group

    or

    myself, Julian

    McMillan.

    22. He

    was

    similarly

    never

    authorized to

    "claim"

    the

    McMillan

    iLaw

    Group

    page

    on

    Yelp.corn.

    23. I note

    that

    the reviews that were

    posted

    to

    yelp.corn

    by

    Marissa

    Famalette

    suggest

    that she

    received

    legal

    services from me.

    By

    virtue

    of the

    California

    Rules

    of

    Professional Conduct

    for

    Attorneys,

    and the

    California

    Business

    and

    Professions Code

    Section

    6068(e)(1),

    I am not able to

    discuss

    any

    legal

    services

    that

    Marissa Famalette, received,

    if

    any.

    24.

    I

    note that

    the reviews

    that were

    posted

    to Yelp.corn

    by

    Ann

    Klock

    suggest

    that she received

    legal

    services from

    me.

    By

    virtue

    of the California

    Rules

    of Professional

    Conduct for

    Attorneys,

    and the

    California Business and

    I

    2O74-OOOO4953

    DBCI.ARATION

    OF JULIAN

    ivICMILLAN

  • 8/10/2019 141114-Yelp McMillan-Filed Decl of Julian McMillan in Supp of Defs' Repl...

    10/14

    I

    Professions

    Code

    Section

    6068(e)(1),

    I am not

    able

    to

    discuss

    any

    legal

    services

    that

    Ann

    Klock,

    received,

    if

    any.

    3

    2S. I note that the reviews that were

    posted

    to

    Yelp.corn

    by

    Eryn

    Sanders

    suggest

    that

    she received

    legal

    services.

    By

    virtue of the California Rules of

    Professional Conduct

    for

    Attorneys,

    and the

    California

    Business

    and

    Professions

    Code Section

    6068(e)(1),

    I am

    not

    able to

    discuss

    any

    legal

    services that

    Eryn

    Sanders, received, if

    any.

    9

    10

    11

    12

    13

    26.

    I

    note that

    the reviews that

    were

    posted

    to Yelp.corn

    by

    Daryl

    P.

    suggest

    that

    she received

    legal

    services from

    me.

    By

    virtue of the Calilornia

    Rules

    of

    Professional Conduct

    for

    Attorneys,

    and

    the

    California

    Business

    and

    Professions

    Code

    Section

    6068(e)(1),

    I am not able

    to

    discuss

    any

    legal

    services

    that

    Daryl

    P.,

    received,

    if

    any.

    I declare under the

    penalty

    of

    perjury

    that

    the

    foregoing

    is true and correct

    and that this

    declaration

    was executed on November

    13,

    2014,

    at San

    Diego,

    California.

    BY

    Iulian MRMillan

    2014-00004P53

    DECLARATION OF JUI.IAN

    MCMPLLAN

    10

    i

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