Transcription of Videotaped Deposition of Ryan Anderson Bell

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 COUNTY OF LOS ANGELES

3
4 MIKE LIN, )
5 Plaintiff, )
6 vs. ) Case No.
7 RYAN ANDERSON BELL; et al., ) BC640744
8 Defendants. )
9 ____________________________)
10 AND RELATED CROSS-ACTION. )
11 ____________________________)
12
13
14 VIDEOTAPED DEPOSITION OF RYAN ANDERSON BELL
15 Irvine, California
16 Monday, April 24, 2017
17
18
19 Reported by: Robin L. Bittel
20 CSR No. 6419
21 Certified Professional
22 Registered Professional Reporter
23
24 JOB No. 2603180
25 PAGES 1 - 83
Page 1
Veritext Legal Solutions

866 299-5127
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 COUNTY OF LOS ANGELES
3
4 MIKE LIN, )
5 Plaintiff, )
6 vs. ) Case No.
7 RYAN ANDERSON BELL; et al., ) BC640744
8 Defendants. )
9 ____________________________)
10 AND RELATED CROSS-ACTION. )
11 ____________________________)
12
13
14
15 Videotaped Deposition of RYAN ANDERSON BELL, taken
16 on behalf of the Plaintiff and Cross-Defendant, at
17 20 Corporate Park, Suite 350, Irvine, California,
18 beginning at 12:55 p.m. and ending at 2:48 p.m. on
19 Monday, April 24, 2017, before Robin L. Bittel,
20 Certified Shorthand Reporter No. 6419, CP, RPR.
21
22
23
24
25
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1 APPEARANCES OF COUNSEL:
2
3 For the Plaintiff and Cross-Defendant Mike Lin:
4 LAW OFFICES OF SETH H. WIENER
5 BY: SETH W. WIENER
6 609 Karina Court
7 San Ramon, California 94582
8 Telephone: (925) 487-5607
9 E-mail: sethwiener@yahoo.com
10
11 For the Defendant and Cross-Complainant
12 Ryan Anderson Bell:
13 JACKSON & WILSON
14 BY: JON MITCHELL JACKSON
15 23161 Mill Creek Drive
16 Suite 150
17 Laguna Hills, California 92653
18 Telephone: (949) 855-8751
19 Facsimile: (949) 855-8752
20 E-mail: mitch@jacksonwilson.com
21
22 Also Present:
23 Mike Lin
24 David Bradley, Videographer
25
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1 I N D E X
3 WITNESS
4 RYAN ANDERSON BELL
5 Examination by: PAGE
6 MR. WIENER 6
9 E X H I B I T S
10 NUMBER DESCRIPTION PAGE
11
12 Exhibit 1 Transcript of a YouTube video 24
13 posted by Ryan Bell on or about
14 February 11 or 12, 2016
15
16
17 WITNESS REFUSES NOT TO ANSWER
18 Page 9, Line 1
19
20
21
22
23
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1 Irvine, California
2 Monday, April 24, 2017, 12:55 p.m. - 2:48 p.m.
4 THE VIDEOGRAPHER: Good afternoon. We're on the
5 record at 12:55 p.m. on April 24th, 2017. This is the
12:55:30
6 video-recorded deposition of Ryan Bell.
7 My name is David Bradley, here with our court
8 reporter, Robin Bittel. We are here from Veritext Legal
9 Solutions at the request of counsel for Plaintiff. This
10 deposition is being held at 20 Corporate Park in Irvine,
11 California. The caption of this case is Lin versus
12 Bell. 12:56:00
13 Will everyone present please introduce
14 themselves, starting with the witness?
15 THE WITNESS: Ryan Bell.
16 MR. JACKSON: Mitch Jackson, counsel for Mr. Bell,
17 both on the answer to the complaint and on the first
18 amended cross-complaint.
19 MR. WIENER: And I'm Seth Wiener. I'm the attorney
20 for Plaintiff and Cross-Defendant Mike Lin.
21 MR. LIN: Mike Lin, plaintiff.
22 THE VIDEOGRAPHER: And will the court reporter please
23 swear in the witness? 12:56:30
24 ///
25 ///
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1 RYAN ANDERSON BELL,
2 a Defendant and Cross-Complainant herein, called as a
3 witness by and on behalf of the Plaintiff and
4 Cross-Defendant, and having been first duly sworn by the
5 Certified Shorthand Reporter, was examined and testified
6 as follows:
8 EXAMINATION
10 BY MR. WIENER:
11 Q. All right.
12 Mr. Bell, did you hear the admonitions that your
13 attorney provided to Mr. Lin earlier about deposition
14 conduct?
15 A. I did.
16 Q. All right.
17 And do you understand those admonitions?
18 A. I do.
19 Q. All right.
20 And I'll -- I'll just incorporate them by
21 reference here.
22 Are you under any medication or substance that
23 would prevent you from giving accurate testimony today?
24 A. No. 12:57:00
25 Q. Is there any other reason why you can't go forward
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1 with your deposition?
2 A. No.
3 Q. All right.
4 Could you state your full legal name for the
5 record?
6 A. Ryan Anderson Bell.
7 Q. And do you go by any other names online?
8 A. No.
9 Q. And what is your date of birth?
10 A. 2-5-77.
11 Q. And where were you born?
12 A. Monroe, Georgia.
13 Q. All right.
14 And what is your spouse's name? 12:57:30
15 A. Lynette.
16 THE REPORTER: Can you spell that, please?
17 THE WITNESS: L-Y-N-E-T-T-E.
18 MR. WIENER:
19 Q. And what date were you married?
20 A. August -- I always mix up my kids' birthdays with
21 our -- August 22nd, 2013.
22 Q. All right.
23 And do you have any children? 12:58:00
24 A. I have two.
25 Q. And how old are they?
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1 A. Two and three now.
2 Q. All right.
3 I'm not going to ask their names.
4 A. Thank you so much.
5 Q. How do you know your attorney, Mitch Jackson?
6 A. Through live video, actually.
7 Q. All right.
8 Have you produced any livestreams, videos or
9 other media for Mr. Jackson?
10 A. No.
11 Q. How did you become acquainted with him through
12 live media? 12:58:30
13 A. Social media, just friendly guy. Actually was
14 friends with my wife first.
15 Q. Apart from this lawsuit, has Mr. Jackson done any
16 other legal work for you?
17 A. No.
18 Q. And could you state your current address?
19 A. I would prefer not to.
20 MR. JACKSON: You can contact the deponent through my 12:59:00
21 law firm. In light of the stalking allegation and some of
22 the other allegations referenced in our cross-complaint,
23 as a matter of professional courtesy, I would ask that we
24 use my law firm's address.
25 MR. WIENER: All right.
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1 I'll -- I'll mark that as a refusal to respond,
2 but we can confer about it. I understand your objection.
3 MR. JACKSON: Okay, although he does reside in
4 Los Angeles or Santa Monica, California.
5 THE WITNESS: That's correct.
7 Q. How long have you resided in Santa Monica? 12:59:31
8 A. A year and a half.
9 Q. And what city did you reside in prior to then?
10 A. Berkeley, California.
11 Q. What years did you live in Berkeley?
12 A. 2000 -- well, I was in Oakland, and I moved to
13 Berkeley. I only lived in Berkeley for 2012 to 2014, I
14 think.
15 Q. All right.
16 And you're a graduate of West Virginia 13:00:01
17 University?
18 A. That's correct.
19 Q. And you obtained your bachelor's degree in
20 marketing and advertising?
22 Q. And do you also have a bachelor degree from the
23 University of Georgia?
24 A. I do not.
25 Q. All right.
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1 Was that incorrectly listed on a LinkedIn
2 profile?
3 A. Yes, it was.
4 Q. All right.
5 Did you attend University of Georgia?
6 A. No, I did not.
7 Q. Do you know how the error came to be --
8 A. No. I've lived in --
9 MR. JACKSON: Is your answer no?
10 THE WITNESS: No. 13:00:34
12 Q. Where are you currently employed?
13 A. Self -- self-employed.
14 Q. And what kind of work do you do being
15 self-employed?
16 A. Virtual reality and social media.
17 Q. When were you last employed by somebody other
18 than yourself?
19 A. 2014? 2014.
20 Q. Do you recall where you received service of 13:01:04
21 process in this lawsuit?
22 A. I'm sorry?
23 Q. Where you were served with the complaint.
24 A. Yes, at an office at VRScout, 12575 Beatrice
25 Avenue.
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1 Q. All right.
2 What is VRScout?
3 A. Media events and production in virtual reality.
4 Q. Is that your company?
5 A. No, it's not.
6 Q. It -- what -- are you employed by VRScout?
7 A. I am considered a consultant there. 13:01:34
8 Q. And you -- you consult with them about virtual
9 reality and social media?
10 A. Uh-huh. I do training and workshops.
11 Q. Is that the address where you -- you work most
12 days?
13 A. It is, yes.
14 Q. All right.
15 Are you also the CEO of a company called BackLamp
16 LLC?
17 A. I was.
18 That company has been sold.
19 Q. Who -- Who is it sold to?
20 A. A company called LiveLeap.
21 Q. What is LiveLeap? 13:02:07
22 A. It is a Facebook syndication software.
23 Q. And when did that sale take place?
24 A. This year.
25 It began February of this year and just
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1 recently -- recently closed.
2 Q. All right.
3 Was Backlamp LLC responsible for Periscope Summit
4 New York? 13:02:37
5 A. It was.
6 Q. All right.
7 Was it also responsible for Periscope Summit SF?
8 A. Yes.
9 Q. And Summit Live LA?
10 A. Yes.
11 Q. As part of the sale, do you -- do you continue to
12 operate Summits, or is that right transferred with
13 Backlamp Summit?
14 A. It's transferred.
15 Q. All right.
16 Are you going to be operating any more Summit
17 events in the future?
18 A. I will be a part of them, but I will not be in
19 charge. 13:03:07
20 Q. What was the sale price for the business?
21 A. $50,000 less 10 percent of things moving
22 forward.
23 Q. All right.
24 Was there supposed to be an event named Summit
25 Live UK?
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1 A. Yes.
2 Q. And was that canceled? 13:03:37
3 A. Yes, it was.
4 Q. Why was it canceled?
5 MR. JACKSON: If you know.
6 THE WITNESS: I don't know.
8 Q. And it -- it's -- is it a correct description
9 that Summit Live is a conference centered around
10 non-traditional media?
11 A. Yes.
12 Q. What is the company called VRSalon?
13 Is that related to VRScout? 13:04:07
14 THE REPORTER: VR -- what was the first one?
15 MR. WIENER: Salon, S-L- -- S-A-L-O-N.
16 THE WITNESS: No, it is not.
17 MR. WIENER:
18 Q. Are you also a 360 VR producer and film director
19 at VRSalon?
20 A. I -- I -- no.
21 Q. All right.
22 Did you list it on your LinkedIn profile?
23 A. I don't know.
24 Q. Did you have any relationship with VRSalon?
25 A. I created it. It's a Twitter handle, basically,
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1 and community. 13:04:37
2 Q. All right.
3 So it's not an actual business entity as far as
4 you know?
5 A. No, no, it's not.
6 Q. What is Zero Moderation?
7 A. It is a nonprofit organization for recovering
8 addicts.
9 Q. All right.
10 And you're a founder of Zero Moderation?
11 A. Uh-huh.
12 Q. What kind of addicts does it assist with
13 recovery?
14 A. It is basically for anyone that has any dealings
15 with alcohol, drug addiction, depression. 13:05:07
16 Q. And what is your role as the founder?
17 A. That is not a very active event anymore. I just
18 created it. It's just something that apparently is on
19 LinkedIn.
20 Q. All right.
21 Did -- did you personally have any alcohol or
22 drug addiction -- addiction issues in your past?
23 A. I did not.
24 Q. Do you currently?
25 A. No. 13:05:37
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1 Q. What decide -- what made you decide to be a
2 founder of a drug and addiction recovery center?
3 A. My wife has a problem -- had a problem.
4 Q. Were you ever arrested for underage drinking?
5 A. Yes, I was.
6 Q. All right.
7 Was there a conviction?
8 A. I don't know. I don't -- I think it was a
9 ticket.
10 Q. All right.
11 Do you have any other felony or misdemeanors
12 convictions? 13:06:07
13 A. No.
14 Q. And how old were you when you obtained -- when
15 that ticket issued?
16 A. 20.
17 Q. All right.
18 Was it in California, or was it in Georgia or
19 somewhere else?
20 A. Georgia.
21 Q. All right.
22 And were you also the regional director at
23 Hypersoft Business Solutions from January 2008 to
24 December 2012? 13:06:37
25 A. Yes.
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1 Q. What was the company that you were working at in
2 2014?
3 A. Insperity.
4 Q. What kind of company was that?
5 A. Basically insurance solutions for small
6 businesses.
7 Q. All right.
8 How do you know my client, Mike Lin?
9 When did you first originally learn of him?
10 A. I heard -- I was interested to him, I believe,
11 because of Scope Day. Limited memory on that one. 13:07:07
12 Q. What is your understanding of what Scope Day is?
13 A. A collection of Periscope enthusiasts doing timed
14 events for one day.
15 Q. Before today, had you ever seen Mr. Lin in
16 person? 13:07:37
17 THE REPORTER: I'm sorry. Before what?
18 MR. WIENER:
19 Q. Today.
20 Had you ever seen Mr. Lin in person?
21 A. No, I had not.
22 Q. Did you ever communicate with him in live time?
23 MR. JACKSON: Objection. Vague and ambiguous.
24 What do you mean by live time?
25 MR. WIENER:
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1 Q. I guess I meant realtime, on the telephone or --
2 A. Telephone, yes, waiting.
3 Q. And what kind of text --
4 THE REPORTER: I'm sorry. I didn't hear the last word
5 you said there.
6 THE WITNESS: Nothing.
7 MR. WIENER:
8 Q. Your answer was yes?
9 A. Yes, yes. Sorry.
10 Q. When was the first time you communicated with
11 Mike Lin via telephone?
12 A. I don't -- I don't have a recollection. 13:08:07
13 Q. Do you know who initiated the call?
14 A. I don't -- I don't recall.
15 Q. Did you ever call Mike Lin?
16 A. I believe I have, yes, in the past.
17 Q. Do you recall approximately the first time you and
18 Mr. Lin had contact?
19 A. I do not.
20 Q. Did you watch any of the livestreams created by 13:08:37
21 Mr. Lin on Periscope?
22 MR. JACKSON: Objection. Vague and ambiguous as to
23 time and scope.
24 MR. WIENER:
25 Q. At -- at -- at any time.
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1 MR. JACKSON: If you recall, if you understand his
2 question.
3 THE WITNESS: Would you repeat the question?
4 MR. WIENER: Sure.
5 Q. Have you ever watched on Periscope any
6 livestreams that were created by Mr. Lin?
7 A. Under Scope Day or just Mike Lin being live? 13:09:07
8 Q. Either of those.
9 A. Yes.
10 Q. Have you read any materials that were drafted by
11 Mr. Lin online?
13 MR. WIENER: Websites, postings on social media sites.
14 MR. JACKSON: Same objection, and I'm placing an
15 objection to preserve my right to do so at time of trial.
16 If you understand the question, you can answer 13:09:37
17 it.
18 THE WITNESS: Next question.
19 MR. WIENER:
20 Q. Well, I would like an answer to that whether you
21 read any of his materials as -- as I defined it. I think
22 I said websites, social media postings.
23 A. I have.
24 Q. Which materials did you read?
25 A. Tweets on his Scope Day Twitter account and the
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1 Scope Day website are what I'm familiar with. 13:10:07
2 Q. All right.
3 Were you a follower of Mr. Lin on his Twitter
4 account?
5 A. Yes, I was.
6 Q. All right.
7 Did you likewise have your own Twitter account?
8 A. Of course.
9 Q. And was Mr. Lin a follower of your account?
10 A. Yes.
11 Q. Does either of you, to the best of your
12 knowledge, still remain a follower of the other?
13 A. I do not believe so.
14 Q. All right.
15 Is it fair to say that Mr. Lin operates in the
16 same general industry that you do? 13:10:39
17 A. No.
18 Q. What do you view is the differences between your
19 respective industries?
20 A. I run physical events.
21 Q. Do you also produce livestreams on Periscope?
22 A. Occasionally I do, yes.
23 Q. All right.
24 And it's correct that Mr. Lin also produces
25 livestreams on Periscope?
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1 A. To the best of my knowledge, yes.
2 Q. Is it -- is it fair to say that you're in the 13:11:09
3 same industry, at least as to livestreams on Periscope?
4 A. No.
5 Q. Why not?
6 A. It's -- it's like saying we're in the same
7 business if we both post things on Facebook. So I use
8 multiple social media assets. I specialize in -- in many,
9 so no. 13:11:43
10 THE REPORTER: In -- you specialize in what?
11 THE WITNESS: In many. Many social-media platforms.
13 Q. On or about February 11th or 12th, 2016, did you
14 post a 12-minute-long videostream about Mr. Lin on
15 Periscope?
16 MR. JACKSON: Do you understand the question?
17 THE WITNESS: I don't know if I --
18 MR. WIENER:
19 Q. In -- in -- in around February 11th or 12th,
20 2016 -- I'll break it out.
21 Did you, at some point, post a videostream about 13:12:14
22 Mr. Lin on Periscope?
23 A. I did, yes.
24 Q. Do you recall the date that you posted it?
25 A. I do not.
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1 Q. When was the last time you watched the video?
2 MR. JACKSON: Objection. Vague and ambiguous as to
3 the term "the video."
4 MR. WIENER:
5 Q. The videostream, the one that was posted on
6 Periscope.
7 A. I didn't watch it.
8 Q. All right.
9 Did you read the transcription of the recording 13:12:46
10 that was produced in this action?
11 MR. JACKSON: Objection. It lacks foundation.
12 The transcript lacks authenticity, and if you're
13 representing to the deponent that that transcript is a
14 transcript of the Periscope, I believe that's a miscorrect
15 or an inaccurate representation.
17 Q. What I'll do first is I'll show you the YouTube
18 video -- video that's posted which -- our -- our position
19 is it's the same as the Periscope. 13:13:16
20 I'd like you to watch it and let me know if you
21 believe that it's materially -- if it's different in any
22 respects from the Periscope video that you posted.
23 THE REPORTER: Are -- do -- are we doing this with me
24 recording?
25 We have to say what we're doing with me.
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1 MR. WIENER: We can take you off the record.
2 THE REPORTER: Okay.
3 MR. WIENER: I -- I don't need you to transcribe it.
4 THE REPORTER: So close -- off the record for this?
5 He has to agree.
6 MR. JACKSON: Sure.
7 Let me just place an objection on the record
8 because I have no idea what you're going to be showing the 13:13:46
9 deponent.
10 So I'll place an objection that it lacks
11 foundation, authenticity. It assumes facts not in
12 evidence. I'll object that it's under the best evidence
13 rule and everything else in between.
14 THE REPORTER: But you're going to run the video?
15 MR. WIENER: Yes, I am, and I'll represent that it's
16 a --
17 THE REPORTER: All right.
18 Tell me when to go off.
19 MR. WIENER: Stay on for one moment.
20 It's a video on YouTube.com, "Watch? 13:14:18
21 B=OWTRX3MT5T0&T=344S," and it's a caption, "Ryan A. Bell,
22 the famous Mike Lin, evidence for the Lin versus Bell
23 lawsuit."
24 THE REPORTER: Off the record?
25 MR. WIENER: Off the record.
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1 (Discussion off the record.)
2 THE VIDEOGRAPHER: Back on the record. The time is
3 1:24 p.m. 13:23:51
5 Q. Mr. Bell, from the portion of the video you saw,
6 was that an accurate video of you discussing Mr. Lin?
7 MR. JACKSON: Do you have a question?
8 THE WITNESS: Yeah.
9 I don't know how to approach that.
10 MR. WIENER:
11 Q. Are those your words coming out of -- is that you
12 depicted in the video? 13:24:21
13 Are you the one speaking?
14 MR. JACKSON: So with respect -- because the
15 question's being asked of the video, let me place an
16 objection once again. The video lacks authenticity,
17 foundation; doesn't comply with the best evidence rule.
18 Having said that, you can answer the question if
19 you understand the question.
20 THE WITNESS: Okay.
21 That looks like me. Yeah, that's me.
22 MR. WIENER:
23 Q. Is that you speaking in the video?
24 A. Yes.
25 Q. Do you believe any of the words were altered or
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1 modified?
2 A. I honestly don't know.
3 Q. Were you reading from a script when you made the 13:24:52
4 video?
5 A. I was not.
6 Q. Did you have any notes of what you were going to
7 say?
8 A. I did not.
9 MR. WIENER: I'm going to mark as Exhibit 1 a
10 transcript of the recording of the portion of which was
11 just shown to Mr. Bell.
12 (Deposition Exhibit 1 was introduced for 13:25:22
13 identification by the Certified Shorthand Reporter and is
14 attached hereto.)
15 MR. WIENER:
16 Q. And, Mr. Bell, if you'd like to have a look at
17 it --
18 A. Not particularly.
19 MR. JACKSON: He may be asking you questions about it.
20 So I'll place an objection to Exhibit Number 1 that it
21 lacks authenticity, foundation; doesn't comply with the
22 best evidence rule. Assumes facts not in evidence.
23 That's for the record.
24 MR. WIENER:
25 Q. Have you read this transcript prior to today?
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1 A. I have not. 13:25:52
2 Q. Can I ask that you do so?
3 It's about eight pages long. So we can go off
4 the record while you read it.
5 MR. JACKSON: Do you want to break it down into
6 sections, or are you going to ask a big, general, global
7 question?
8 MR. WIENER: I'm going to ask both global and specific
9 questions about those statements made therein.
10 MR. JACKSON: So are you using this document to
11 refresh his recollection about something?
12 MR. WIENER: Right.
13 I -- I just want him to remember if this is his
14 video, or if he believes it's not an accurate
15 transcription of what he stated on that day, I'd like him 13:26:22
16 to know that as well.
17 MR. JACKSON: Okay.
18 Because you can ask those questions without him
19 looking at --
20 THE WITNESS: I just watched the video.
21 MR. JACKSON: -- the document in front of you.
22 MR. WIENER: Well, I -- I --
23 MR. JACKSON: It's your deposition.
24 MR. WIENER: I -- I want to have a record that that is
25 an accurate transcription of the video that I just showed
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1 him as well.
2 I mean, I -- I don't think it should be
3 controverted that it -- it -- it's an actual, but
4 you're -- you're objecting based on best evidence, and
5 I'm trying to lay a foundation for it. I'm not too sure 13:26:52
6 how else to go about it.
7 MR. JACKSON: Right.
8 So I'll place my objection. I'll let -- it's
9 your deposition. I'll let you ask any questions you
10 want.
11 My objection is that it lacks foundation,
12 authenticity. Best evidence rule. Assumes facts not in
13 evidence, probably in addition to other evidence issues.
14 So if Counsel wants you to look at that, then go
15 ahead and look at it.
16 THE WITNESS: All right.
17 MR. WIENER: 13:28:08
18 Q. Have -- have you reviewed the transcript?
19 A. I have.
20 Q. Do you believe it's an accurate transcript of
21 your oral statements?
22 A. It seems to represent what was on video.
23 Q. Do you believe the video was an accurate recording
24 of you speaking?
25 A. I do not. I do not recall the -- I -- I just
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1 don't know if that video is, you know, completely
2 untampered with. I don't know the source of that video at 13:28:38
3 all.
4 Q. Do you have any original copies of the video?
5 A. No. That was not -- that was a private video.
6 Q. Where was the video broadcast?
7 A. Periscope.
8 Q. All right.
9 And there's no -- you don't have any recordings
10 of it in your own possession, custody or control?
11 A. No. It's just what you put on --
12 MR. JACKSON: You should answer yes or no.
13 THE WITNESS: No.
14 MR. WIENER:
15 Q. Are there any specific statements that are
16 contained in the video or the transcript that you believe 13:29:08
17 you did not make?
18 A. I don't know.
19 Q. Do you believe that Mr. Bell somehow
20 transcribed --
21 A. Mr. Lin you mean.
22 Q. Yeah. I'm sorry.
23 That Mr. Lin somehow changed your monologue from
24 the video?
25 MR. JACKSON: Objection. Calls for speculation as to
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1 what Mr. Lin did or didn't do. It also assumes facts not
2 in evidence because apparently somebody else transcribed 13:29:38
3 the -- some video.
5 Q. Do you agree that, from the video you watched --
6 that that is an accurate transcription of the video that
7 was on YouTube?
8 A. That is an accurate transcription of the video
9 that I just watched.
10 Q. All right.
11 And you're not sure if the video that you posted
12 on Periscope is the same as the video you saw on YouTube?
13 A. I am positive it is not the same video that I
14 posted on Periscope. 13:30:08
15 Q. And what makes you positive about that?
16 A. None of the engagement or comments or anything
17 were on there, and it also was very jumpy and jerky, and
18 it -- it had a lot of places where things were cut out and
19 blurred. It was very odd video if you look at it.
20 Q. Do you -- do you recall how long the video was
21 that you created on February -- in February 2016 about
22 Mr. Lin?
23 A. I do not.
24 Q. Do you believe this video was edited?
25 MR. JACKSON: And don't guess. 13:30:38
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1 It calls for speculation. Objection. Calls for
2 speculation.
3 THE WITNESS: I don't -- yeah, I -- I don't recall it.
4 MR. WIENER:
5 Q. What materials do you believe were added to the
6 video that you didn't have in the original video?
7 A. This was a year and a half ago. I don't know.
8 Q. Who recorded the video?
9 MR. JACKSON: What video?
10 MR. WIENER:
11 Q. The one that you posted on Periscope.
12 A. Oh, I -- I did. It was directly to Periscope, 13:31:08
13 and then it was deleted.
14 Q. What date did you delete it?
15 A. The exact same day right after I did it.
16 Q. And -- and how many hours was it posted online?
17 A. Less than three but probably less than two.
18 Q. All right.
19 Who actually recorded it, though?
20 Was there someone other than you holding the
21 camera?
22 A. It was my phone on a mount, I believe. I have
23 multiple mounts because I do multiple Periscopes, or did.
24 I don't anymore, thanks to the trolling. 13:31:38
25 Q. All right.
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1 At the end of the video, somebody says, quote,
2 "And we're done. Okay. That was boring as shit."
3 Is that you speaking or somebody else?
4 MR. JACKSON: Objection. Assumes facts not in
5 evidence. It assumes he recalls saying anything during
6 this video.
7 THE WITNESS: I don't -- I don't recall.
8 MR. WIENER:
9 Q. Do you recall if you were alone when the video
10 was made?
11 A. My wife was in the -- in the living room. That
12 was in the living room. My wife was reading. 13:32:08
13 Q. Okay. All right.
14 She wasn't involved in shooting the video,
15 though?
16 A. Not at all, no.
17 Q. All right.
18 You thanked -- on page 7 of the transcription,
19 you said, "Thank you, Amber. Thanks, guys. Thanks,
20 Jenna."
21 Who were you speaking to?
23 evidence.
24 MR. WIENER:
25 Q. Did -- did you make those statements?
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1 A. I don't recall.
2 Q. Do you know someone named Amber? 13:32:38
3 A. I do know multiple people named Amber.
4 Q. Do you recall why you would have -- if this --
5 all right.
6 So is it your testimony that nobody was present
7 for the recording of the video except for you?
8 A. In the room, except for my wife.
9 Q. All right. 13:33:08
10 And she didn't record the video, though, is your
11 testimony?
13 Q. Well, why did you decide to take down the video
14 after about three hours?
15 A. I had said what I needed to say.
16 Q. Why did you need to make any statements about
17 Mr. Lin? 13:33:38
18 A. I'm sorry?
19 Q. Why did you need to make any statements about --
20 about Mr. Lin?
21 A. I had been approached by multiple females who he
22 was harassing.
23 Q. Who were those females?
24 A. I would definitely prefer not to say in present
25 company.
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1 Q. There are persons who made accusations against
2 my client. I -- I believe I'm entitled to their names.
3 A. I am not a danger.
4 Q. But Mr. -- 13:34:13
5 THE REPORTER: Pardon me. I'm sorry. Repeat that. I
6 need you to repeat what you said.
7 THE WITNESS: I said -- I said I am not a danger.
8 MR. JACKSON: So, Mr. Bell, if you recall the names of
9 the individuals Counsel asked you about, it's perfectly
10 acceptable for you to respond to his question if you
11 recall their names.
12 Otherwise, Counsel will get a court order, and a
13 judge will order you to answer the question. So if you
14 recall their names, you can share them with Counsel.
15 If you don't recall their names, then just let
16 Counsel know. And if you want to take a break and talk
17 about it, we can do that too.
18 THE WITNESS: I do not want to give names of any
19 females in front of Michael Lin. 13:34:54
20 MR. WIENER: The deposition is being recorded. And, I
21 mean, to the extent they've made accusations against my
22 client, he is entitled to know who they are. They're
23 potentially witnesses.
24 THE WITNESS: They're potentially in danger too.
25 MR. JACKSON: Why don't we take a quick break --
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2 MR. JACKSON: -- and let me talk to my client?
3 THE VIDEOGRAPHER: We're going off the record. The
4 time is 1:35 p.m.
5 (Recess taken.)
7 1:39 p.m. 13:39:03
9 Q. Who are the women who complained to you that they
10 were harassed by Mr. Lin?
11 A. Lizza Morales, Jenny Q.
12 Q. How do you spell Q?
13 A. It's -- I -- I don't know. It's a social media
14 handle. I -- I can't remember at the moment. Just Jenny 13:39:33
15 Q is one of them.
16 THE REPORTER: Are you saying Jenny?
17 THE WITNESS: Yeah, Jenny, J-E-N-N-Y, I'm pretty
18 sure.
19 Amber Plaster. I can't remember her last name.
20 There's a few more. I can't -- I can't remember their
21 names. Those are the ones that I remember offhand. I'd
22 have to look up and go back through e-mails for all the 13:40:03
23 complaints.
25 Q. Did they send you any e-mails specifically
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1 regarding Mr. Lin?
2 A. A lot of them were phone calls, actually.
3 Q. All right.
4 Are there any e-mail records -- records of
5 e-mails you received from third persons concerning
6 harassing conduct by Mr. Lin?
7 A. Twitter DMs, probably not any e-mails. I
8 think -- I don't think I can -- I think I can produce any
9 e-mails. 13:40:33
10 Q. Are you able to produce Twitter DMs?
11 A. More than likely I probably can.
12 Q. All right. We -- we would like those.
13 Was -- what type of complaints did Ms. Morales
14 make against Mr. Lin?
15 A. It's so long ago. The racist remarks, trolling,
16 just general harassment was the entire theme of Mr. Lin.
17 Q. And that was the common complaint among all --
18 all the women? 13:41:05
19 A. Some -- some -- some were sexual advances or
20 unwelcome sexual advances, especially with younger --
21 younger women.
22 Q. What kind of sexual advances?
23 A. Just making lewd inappropriate conducts to people
24 that were either married or very young.
25 Q. Were any of them under the age of 18?
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1 A. Yes.
2 Q. Which ones?
3 A. I can't remember the name. 13:41:35
4 Q. Well, why did these persons make complaints to
5 you?
6 MR. JACKSON: Objection. Calls for speculation.
7 You can answer the question if you understand it.
8 THE WITNESS: I led the conference, and I'm seen as a
9 community leader, I think.
10 MR. WIENER:
11 Q. What conference are you referring to?
12 A. The Summit conference in -- in Periscope Summit.
13 Q. And was Mr. Lin a participant in that 13:42:06
14 conference?
15 A. No. He was not --
16 MR. JACKSON: Try to answer yes or no. It's a
17 yes-or-no question.
18 THE WITNESS: So it's a -- it's a -- there -- there
19 were three different conferences.
20 MR. WIENER:
21 Q. And was Mr. Lin a participant in any Summit Live
22 conferences?
23 A. He was.
24 Q. Which one?
25 A. The San Francisco.
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1 Q. Do you have any -- most of these communications
2 were via telephone or via Twitter? 13:42:38
3 A. Correct.
4 Q. Did you tell any of the women that you would take
5 any kind of action against Mr. Lin?
6 A. No.
7 Q. Did you ask any of them to watch this video?
8 A. No.
9 Q. Do you have a FullScope.TV account?
10 A. I had one at one time. I don't know if it's
11 still valid or used.
12 Q. When did you have the FullScope.TV account?
13 A. I don't know. 2015 for -- but I -- I don't think 13:43:08
14 I -- I only used it maybe twice. It's just a metrics
15 tool, I believe.
16 Q. Do you know if it produces recordings of
17 livestreams?
18 A. I don't think it does.
19 Q. What was the process by which you uploaded the
20 livestream about Mr. Lin onto Periscope?
21 MR. JACKSON: Objection as to the term "upload." I 13:43:38
22 think that incorrectly -- incorrectly describes how the
23 Periscope app works, but having placed that objection on
24 the record, you can answer the question.
25 THE WITNESS: It was directly done through Periscope,
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1 which is a video app.
2 MR. WIENER:
3 Q. And so it is recorded by a telephone?
4 A. Telephone. That's correct.
5 Q. Does that actually produce a recording, or does
6 it transmit directly to Periscope?
7 A. It transmits directly to Periscope at the time.
8 The recording lasts for 24 hours. 13:44:08
9 Q. The recording lasts for 24 hours on your
10 telephone?
11 A. On Periscope.
12 And then it -- I -- and then it was deleted, but
13 I deleted it way prior to that 24-hour mark.
14 Q. What kind of phone did you use to --
15 A. iPhone 6 or 6 Plus, probably 6 Plus.
16 Q. All right.
17 There's no recording of the video you created on
18 that telephone?
19 A. No, sir.
20 Q. Why did you choose to delete the video?
21 A. Because I said what I needed to say. 13:44:39
22 Q. And that was to protect the women?
23 A. Yes.
24 Q. How do -- how do you protect them, though, if you
25 deleted the video several hours after making -- making it?
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1 MR. JACKSON: Objection. Argumentative.
2 You can answer the question if you understand it.
3 THE WITNESS: Repeat the question.
4 MR. WIENER:
5 Q. Well, how specifically did the video protect the
6 women who allegedly complained about Mr. Lin?
7 A. If a few of the people that followed me knew,
8 then they would be able to -- you know, knowledge is 13:45:09
9 power.
10 Q. Did you have -- the other people would
11 rebroadcast the video?
12 A. No.
13 Q. Do you know how many people viewed the video in
14 the three hours that it was on online?
15 A. I have no idea.
16 Q. Is it correct -- do you believe that more people
17 would have viewed the video had it been left online for
18 longer than three hours?
19 MR. JACKSON: Objection. Calls for speculation.
20 THE WITNESS: I don't know. 13:45:39
21 MR. WIENER:
22 Q. Where did you obtain the information that you
23 stated about Mr. Lin in the video?
25 What information are you referring to --
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1 MR. WIENER: All right --
2 MR. JACKSON: -- when you say -- when you use the word
3 "stated"?
4 MR. WIENER:
5 Q. For -- for example, at the time you made the
6 video, did you believe that Mr. Lin had worked at
7 LinkedIn? 13:46:09
8 MR. JACKSON: That's a separate question than what may
9 or may not be on the video.
10 MR. WIENER:
11 Q. I'll -- I'll -- I'll go through each -- each of
12 the statements.
13 A. That would be good.
14 Q. All right.
15 MR. JACKSON: Counsel, the reason I'm -- I'm bringing
16 this to your attention is -- is the deponent doesn't
17 recall what was or was not said on the Periscope video.
18 So I don't know if you're asking him about that
19 or what in the documentation that you handed to him
20 earlier in the deposition, or is this just an open-ended
21 question?
22 MR. WIENER:
23 Q. I'm -- I'm going to refer to the transcription
24 that's there, but if -- if you don't believe you made the 13:46:39
25 statement, you can state that as well.
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1 MR. JACKSON: Or recall making the statement.
2 MR. WIENER: Right. Right.
3 Q. Do you recall making a statement in your video
4 that -- in the livestream that Mr. Lin is, quote, a felon?
6 Q. Do you have reason to believe that Mr. Lin is a
7 felon?
8 A. I don't recall. I had a lot of conversations
9 with Mr. Lin.
10 MR. JACKSON: Do you mean "as you sit here" -- sits
11 here today?
12 MR. WIENER:
13 Q. As you sit here today, do you have any reason to 13:47:10
14 believe that Mr. Lin is a felon?
15 A. I don't recall. I --
16 Q. Do you recall if in your -- in -- in the
17 livestream you made a statement that Mr. Lin is, quote,
18 mentally disturbed?
20 Q. Do you have any reason to believe that Mr. Lin is
21 mentally disturbed?
22 A. I do.
23 Q. What -- what -- what is the -- that basis?
24 A. His admission of being 5150'd multiple times and
25 institutionalized and his personal conversations via
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1 telephone with me about his mental issues. 13:47:40
2 Q. And why did you think it was necessary to
3 rebroadcast those?
4 MR. JACKSON: Objection. That assumes facts not in
5 evidence.
7 THE WITNESS: I just --
8 MR. JACKSON: And it's argumentative.
9 You don't have to answer that last question.
10 MR. WIENER:
11 Q. In -- in -- in February 2016, did you believe
12 Mr. Lin was mentally disturbed?
13 A. I do, and I still do. 13:48:10
14 Q. Do you believe he's a psychopath?
15 A. Could you define "psychopath" for me?
16 Q. Is that a word that you've used in reference to
17 Mr. Lin?
18 A. I don't recall using that word.
19 Q. Do you recall using the word "sociopath" to refer
20 to Mr. Lin?
21 A. I don't recall using that word either.
22 Q. Do you recall ever stating that Mr. Lin is,
23 quote, not allowed in America?
25 Q. In February of 2015, are -- as we sit here -- in 13:48:41
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1 February 2015, did you have any reason to believe that
2 Mr. Lin was not allowed in -- in America?
3 MR. JACKSON: '15 or '16?
4 MR. WIENER: '16. I'm sorry. Thank you.
5 THE WITNESS: Mr. Lin did tell me that he had -- he
6 was taken out of America so that he would not be
7 institutionalized. That's -- so that's directly from a
8 phone call with Mr. Lin.
9 MR. WIENER:
10 Q. Did you believe there was a court order or some
11 kind of judicial or legislative process that forbid
12 Mr. Lin from reentering America? 13:49:11
13 A. From my understanding from Mr. Lin, he needed
14 to be away from the USA so that he wouldn't be
15 institutionalized, from a phone conversation directly with
16 Mr. Lin.
17 Q. All right.
18 Did you also -- did you make a statement that --
19 in February 2016 that -- to the effect that a lot of
20 SexBots are Mr. Lin? 13:49:41
22 Q. Do you know what a SexBot is?
23 A. A fake account that is -- like a Russian -- has a
24 Russian sexy name, I believe.
25 Mr. Lin had admitted to me about having multiple
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1 accounts that he used to harass people or troll people on
2 Twitter.
3 Q. Do you recall if any of those accounts Were
4 SexBots? 13:50:11
5 A. All I know is he has, you know, multiple accounts
6 for the express purpose of trolling and harassing.
7 Q. What do you mean by express purpose?
8 Did Mr. Lin tell you that was the express purpose
9 of the accounts was to use them to harass people?
10 A. He told me that he used them to harass people.
11 Q. Did he ever personally use any accounts to harass
12 you? 13:50:41
13 A. It is a very safe assumption, yes.
14 Q. Do you have any concrete information that he did
15 use his accounts to harass you?
16 A. I -- I don't recall. I -- I -- I stopped being
17 on Periscope because of Mr. Lin. I very rarely broadcast
18 because of him.
19 Q. When did you stop being on Periscope?
20 A. I'd say I broadcast maybe once a month now. I
21 used to broadcast daily. 13:51:11
22 Q. All right.
23 In -- in February 2016, did you know that Mike
24 Lin had worked at LinkedIn?
25 A. I did. He says it often.
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1 Q. All right.
2 Did you make a statement that Mike Lin used
3 LinkedIn information to gain mortgage information?
5 Q. Do you have any reason to believe that Mr. Lin did
6 use LinkedIn to get people's mortgage information?
7 MR. JACKSON: As we sit here today? 13:51:41
8 MR. WIENER: Yes.
9 MR. JACKSON: So that question excludes any
10 information you've received from counsel from my office on
11 that issue. Just so we're clear, it's protected by
12 attorney-client product -- attorney-client privilege and
13 attorney work product.
14 THE WITNESS: Right. 13:52:11
15 MR. JACKSON: So you can answer Counsel's question if
16 you're able to.
17 THE WITNESS: A female reached out to me, saying that
18 he -- he had gotten her -- her physical address and was
19 threatening to throw a party at her house.
20 Of course, this was a person that did not want to
21 have a social party at her -- at her house, but that was a
22 threat that Mike Lin threatened her with.
23 MR. WIENER: 13:52:41
24 Q Do you know if that information, her physical
25 address, somehow came from LinkedIn?
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1 A. She said that he told her it was from LinkedIn.
2 Q. Do you know if LinkedIn, based on your knowledge,
3 provides physical addresses for individuals?
4 A. I don't know. I -- I don't think it does. I
5 don't know.
6 Q. All right.
7 Do you know if LinkedIn provides phone numbers
8 for individuals?
9 A. Yes, it does.
10 Q. It -- that's in their account profiles?
11 A. You have the option to put your phone number in. 13:53:11
12 Q. All right.
13 Did you claim that Mr. Lin used LinkedIn
14 privileges to get the telephone numbers?
16 Q. Do you recall if Mike Lin had some special
17 privileges at LinkedIn after he stopped working there?
18 A. Mike Lin told me -- yes, Mike Lin told me that he
19 had special LinkedIn privileges. 13:53:41
20 Q. When did you have that discussion with Mr. Lin?
21 A. I don't recall exact dates. This was a long time
22 ago.
23 Q. Did you ever make any statements that Mr. Lin had
24 run away to Taiwan so he would not be committed for being
25 a danger to his own family?
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1 A. I don't recall. 13:54:11
2 Q. Do you recall if you ever made any statements
3 that Mr. Lin was hiding out in Taiwan in his parents'
4 basement?
6 Q. Do you know what -- what kind of residence
7 Mr. Lin's parents had in Taiwan?
8 A. I don't recall or care.
9 Q. So if -- if that statement was made by you that
10 he is hiding out in Taiwan in his parents' basement, you
11 didn't care if it was true or not? 13:54:41
12 A. I don't recall --
13 MR. JACKSON: Objection. Calls for speculation,
14 assumes facts not in evidence, argumentative.
15 MR. WIENER:
16 Q. At the time prior to posting a video about
17 Mr. Lin on Periscope, what efforts if any did you make to
18 verify the accuracy of any statements he made? 13:55:11
19 MR. JACKSON: Objection. Assumes facts in evidence,
20 lacks foundation, assumes the deponent recalls statements
21 made. I think he's testified he doesn't recall.
22 So how can he answer questions about --
23 MR. WIENER: I -- I --
24 MR. JACKSON: -- something he doesn't recall?
25 MR. WIENER:
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1 Q. Do you recall posting some video about Mr. Lin in
2 early February 2016?
3 A. I do.
4 Q. And you recall making some statements about
5 Mr. Lin; correct?
6 A. I do. 13:55:41
7 Q. Do you recall what efforts if any you made to
8 verify that any of the statements were true?
9 A. Anything I've said about Mike Lin has come
10 basically directly from Mike Lin.
11 Q. And do you have -- when you say it came from
12 Mr. Lin, did it come from oral conversations with Mr. Lin,
13 or did it come from e-mails or Twitter?
14 A. Mostly oral conversations.
15 Q. Do you have any way of tracking how many people 13:56:11
16 viewed the Periscope -- Periscope stream that you created?
17 A. Zero way of telling.
18 MR. JACKSON: It's a yes-or-no question.
19 THE WITNESS: No, I have no way to track.
20 MR. WIENER:
21 Q. Do you know if the videostream has been
22 republished on any other websites besides YouTube? 13:56:41
24 evidence that it was republished.
25 You can answer the question.
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1 THE WITNESS: Answer -- ask the question one more
2 time.
3 MR. WIENER:
4 Q. Do you know if it's been republished on any
5 websites?
6 MR. JACKSON: Same objection.
7 THE WITNESS: I don't.
8 MR. WIENER:
9 Q. At the time you posted the video, did you believe
10 that Mr. Lin was emotionally vulnerable? 13:57:11
11 A. I believe Mr. Lin has been emotionally vulnerable
12 since the first day I talked to him.
13 Q. All right.
14 Did you consider what impact the -- posting the
15 livestream might have on his psyche?
16 A. I did.
17 Q. What did you think the impact would be?
18 A. I had hoped that Mike Lin would get off of social 13:57:41
19 and get actual help for a very long time. His problem is
20 that he's trying to be on social instead of getting help.
21 Q. Did you create this livestream with the hope
22 that it would encourage him to obtain mental health 13:58:12
23 services?
24 A. I would love to see that. I told him that
25 multiple times prior to him attacking me.
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1 Q. How do you believe Mr. Lin attacked you?
2 A. Harassing me via livestream, making fake Bitly
3 accounts to drive traffic and drive money away from my 13:58:44
4 business, saying bad things about me on social, all these
5 things that I can handle.
6 Q. When you put the livestream on Periscope, did you
7 put it for public or private broadcast? 13:59:14
8 A. I believe that I put it private. At the time, I
9 had 17,000 followers.
10 Q. How many followers do you have now on Periscope?
11 A. 21,000.
12 It's just like Twitter.
13 MR. JACKSON: You answered his question.
14 THE WITNESS: All right. 13:59:44
15 MR. WIENER:
16 Q. Do you regret having posted the Periscope
17 livestream concerning Mr. Lin?
18 A. I do.
19 Q. Why do you regret it?
20 A. I had hoped that it would help people and not
21 harm Mike, and I would prefer to not be here right now. 14:00:14
22 Q. Did you make any efforts to apologize to Mr. Lin
23 before this lawsuit was filed but after the livestream was 14:00:46
24 posted or went on Periscope?
25 MR. JACKSON: Apologize for what reason?
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1 MR. WIENER:
2 Q. You -- your --
3 MR. JACKSON: So objection. Argumentative.
4 MR. WIENER:
5 Q. You said, correct, that you regretted having
6 posted the livestream on Periscope? Correct?
7 A. I did.
8 Q. Did you apologize to Mr. Lin for having posted 14:01:16
9 it?
10 A. No.
11 Q. Was there a reason why you didn't?
12 A. Mr. Lin has never once let up on attacking me.
13 Q. And how do you think Mr. Lin attacked you prior
14 to February 2017?
15 A. The Bitly link that was a direct way to take
16 money away from my business, attacking me via alternate
17 accounts on my -- on my social, sending me odd e-mails 14:01:46
18 with quotes and song lyrics that were threatening, like
19 "For Whom the Bell Tolls" and "Number 1 with a Bullet,"
20 lots and lots of threatening scary things that scared me
21 and my wife.
22 Q. How did Mr. Lin specifically attack you on social
23 media accounts? 14:02:16
24 A. Tweeting things.
25 I think he had the hash tag
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1 "forwhomthebelltolls," which is really scary when you know
2 that someone is disturbed and they're sending you things
3 about death to you and your family. It's scary.
4 Q. Did you seek any -- any kind of temporary
5 restraining order against Mr. Lin?
6 A. I called the police, and I had to move. 14:02:46
7 Q. When did you contact the police?
8 A. When he was at the same event as my wife and also
9 when he was outside of my -- my office.
10 Q. What event did Mr. Lin -- I'll get to this
11 after, actually.
12 Did you tell any persons to delete Mr. Lin's
13 Scope Day account?
14 A. I do not recall.
15 Q. Did you tell any persons to block Mr. Lin's Scope
16 Day account? 14:03:16
17 A. I do not recall that.
18 Q. Do you have a belief one way or another as
19 whether you did that?
20 MR. JACKSON: Objection. The question has been asked
21 and answered. He doesn't recall.
22 THE WITNESS: I don't recall.
24 Q. Did you review the first amended cross-complaint
25 in this action prior to it being filed?
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1 A. I don't recall. But, yeah, that sounds kind of
2 legal mumbo-jumbo to me.
3 Q. Do you recall that you filed a cross-complaint? 14:03:46
4 A. Oh, oh, sorry. Yes, yes, yeah, I do.
5 Q. All right.
6 Did you review it prior to it being filed?
7 A. Yes, I did.
8 Q. Did you believe those statements or the
9 allegations in the first amended cross-complaint were true
10 and accurate?
11 A. Yes.
12 Q. What threatening and disgusting remarks do you
13 believe Mr. Lin made about you?
14 A. Mr. Lin is -- I don't like repeating things that
15 he says on livestream, but usually it's about raping 14:04:16
16 children or raping pigs or some type of anal raping and
17 bleeding. That's Mr. Lin's go-to.
18 Q. When did he -- when did he allegedly make
19 statements to that effect?
20 A. I don't recall. 2016?
21 You know, I -- like I said, I don't really go on
22 Periscope much anymore because of that.
23 Q. How do you know the statements were made by 14:04:46
24 Mr. Lin?
25 A. Tracking which accounts.
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1 A lot of -- if you look at his accounts, a lot of
2 them will have a fist as the profile picture, and he does
3 the same thing to other people. So you can usually tell
4 by bloody child rape or pig rape or anal sex that it's
5 Mike Lin. 14:05:16
6 Q. Are -- are there any specific accounts where you
7 believe he used to make statements to that effect?
8 A. He admits to having 500 something accounts. I
9 believe he has more. There's -- there's no telling
10 what -- which account, if it's the Sex_TV or the whatever
11 account. I -- I don't know.
12 Q. How do you know any account specifically
13 associated with Mr. Lin was used to make any statements to
14 that effect, though? 14:05:46
15 A. A lot of times he will even call himself out and
16 say that it's Mike Lin. So you can track which accounts
17 he's saying it on. Most people know.
18 Q. Do you have any screenshots of an account making
19 a statement about anal sex that is an account that you
20 believe is Mr. Lin?
21 A. I don't know if I do or not. I may.
22 Q. All right.
23 And you were requested to produce all documents
24 regarding the allegations in your first amended cross --
25 or in your cross-complaint; correct? 14:06:16
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1 A. Yes.
2 Q. When did you make a police report concerning
3 Mr. Lin?
4 A. I don't recall the dates. I -- I can probably
5 find it out because of the event.
6 Q. Did they provide any -- did the police provide
7 any -- which police department did you refer to?
8 A. Santa Monica. 14:06:46
9 Q. Did they provide any incident report or a case
10 number to you?
11 A. I don't think so.
12 Q. Was any report made about the complaint?
14 Q. Was there a specific police officer investigating
15 the allegations?
16 A. I don't recall his name.
17 Q. Was any arrest warrant issued?
18 A. No. I didn't pursue it.
19 Q. Did Mr. Lin ever tell you to prepare for hell?
20 A. Yes. 14:07:26
21 Q. When did he make that statement to you?
22 A. Shortly after the San Francisco Summit event.
23 I remember the very scary things.
24 Q. What was the context in which he made that
25 statement?
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1 A. This was during a barrage of madness during all
2 the times that he sent me the song lyrics. I -- I -- I --
3 there's really not much context to or rhyme or reason to 14:07:56
4 what was happening then. I was just scared.
5 Q. Did you understand that Mr. Lin was threatening
6 you with litigation, or you interpreted it as something
7 else?
8 A. He was threatening -- threatening me with -- I --
9 I thought he was threatening me with my life. "Prepare 14:08:26
10 for hell," "For Whom the Bell Tolls." I -- I was -- I
11 felt fearful for my family and for myself.
12 Q. Did he make that statement in writing or was that
13 verbally?
14 A. Verbally, and there are some in writing of song
15 lyrics and stuff.
16 Q. I've seen the song lyrics, but the specific
17 statement "prepare for hell," was that via e-mail,
18 Twitter, some other media?
19 A. I believe it was Twitter. I -- I -- I don't
20 recall exactly, but like there was -- those were the word 14:08:56
21 tracks.
22 Q. Was that a statement made directly to you or to
23 your attorney?
25 Q. Did Mr. Lin threaten to spend 10,000 on Facebook,
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1 YouTube and LinkedIn to harm you?
2 A. Yes, he did.
3 Q. Did you understand that was a threat of physical
4 harm or that he would post statements about you?
5 A. That was a threat of social media harm. That was 14:09:26
6 not anything that -- I was scared of bodily harm.
7 Q. All right.
8 You also claim Mr. Lin made harassing telephone
9 calls to you?
10 A. Yes.
11 Q. When did -- Do you recall what telephone number
12 he used for those telephone calls?
13 A. Multiple different phone numbers.
14 Q. Do you have any telephone records that
15 indicate what was your receiving number on -- on those
16 calls?
17 A. (415) 939-7210.
18 Q. That was the only number that you allegedly
19 received calls on from Mr. Lin? 14:09:59
21 Q. Do you have any telephone account records relating
22 to that telephone number?
23 A. I mean, of course. I have every month's bill.
24 Q. Who is the carrier on it?
25 A. Verizon.
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1 Q. Is -- is it a cellular phone?
2 A. Yes.
3 Q. Are you able to produce those telephone
4 records?
5 You can redact any telephone numbers that you
6 don't believe were calls from Mr. Lin from it. 14:10:29
7 MR. JACKSON: Before you answer that question, make
8 sure you got the document. Otherwise, they can get them
9 directly from Verizon. I don't want you to make a
10 promise, then go home and realize you don't have the
11 documents.
12 THE WITNESS: I don't -- I don't have the
13 documents.
14 You can go get them from Verizon; right?
15 MR. JACKSON: I don't know. I'm not answering the
16 question for you. I just want to make sure -- if you
17 represent to Counsel you've got the documents, then make
18 sure you've got them.
19 MR. WIENER:
20 Q. Well, what I'm trying to do is preserve your
21 privacy. I -- I can certainly subpoena the records from 14:10:59
22 Verizon.
23 A. Okay.
24 Q. But then it's going to show the phone numbers of
25 persons I don't care about, and you probably don't want me
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1 to know who else you're getting calls from.
2 I'll represent to you that if you go onto your
3 account with Verizon, it will let you download probably
4 about at least a year or possibly two years of cellphone
5 records that shows any calls you've received.
6 A. Can I interject and say that I think that this
7 would be not -- a really difficult thing to do because 14:11:29
8 there's so many different numbers that call -- call me.
9 It would be impossible to say, "Hey, this is
10 where this happened."
11 MR. JACKSON: So -- so why don't we back up and let
12 Counsel ask a question --
13 THE WITNESS: Sorry.
14 MR. JACKSON: -- since this is just a deposition?
15 THE WITNESS: My fault. Yeah.
16 MR. JACKSON: We're not producing documents today.
17 THE WITNESS: Okay.
18 MR. JACKSON: And let's start over.
19 THE WITNESS: Sorry.
20 MR. WIENER:
21 Q. How long were the telephone calls to -- that you
22 received from Mr. Lin?
23 A. The regular normal conversations back when we
24 were friends? 14:12:00
25 Q. During what period of time were you friends?
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1 I haven't used -- heard you use that term
2 previously in reference to Mr. Lin.
3 A. Probably three months prior to the January event
4 in 2016.
5 So I would say I was very kind and nice to
6 Mr. Lin at that point in time.
7 Q. All right.
8 And excluding phone calls during that period, but 14:12:30
9 the harassing phone calls began in about January 2016?
10 A. Directly after the event.
11 Q. And how long were those calls typically?
12 A. They were only prank calls. They were short
13 calls that I'd hang up on.
14 Q. Did you ever seek to block any telephone numbers 14:13:00
15 during that time period?
16 A. I did. I continue to. He has -- he has harassed
17 me a whole lot.
18 Q. Do you believe that Mr. Lin continues to call you?
19 A. I do.
20 Q. How frequently?
21 A. I don't know.
22 Q. Did you accuse Mr. Lin of adding your telephone
23 number to a call list?
24 A. I did. 14:13:30
25 Q. Which call list were you referring to?
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1 A. I don't think that there is a universal call
2 list. I think that there are multiple call lists that
3 Mr. Lin has put me on.
4 Q. Telemarketing call lists?
5 A. Yeah, fun stuff.
6 Q. And how many call lists do you estimate you've
7 been added to?
8 A. Dozens.
9 I had to get another phone number.
10 Q. Have you sought to have your old phone number
11 added to the "Do Not Call" list? 14:14:00
12 A. I have.
13 Q. All right.
14 And that didn't prevent the calls?
15 A. You know it doesn't.
16 Q. Can you provide a couple of examples of call
17 lists that you believe you were added to?
18 A. Student loan, Cash for Gold.
19 You name it; I'm on it.
20 Q. Is your current phone number unlisted?
21 A. No, it's -- I -- I -- I don't know if it's listed
22 or not. I don't know. 14:14:30
23 Q. Is there any reason --
24 MR. JACKSON: Make sure you speak up so the court
25 reporter can hear you.
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1 THE WITNESS: I'm sorry. My fault.
2 MR. JACKSON: We're good.
3 MR. WIENER:
4 Q. Is there any reason why you wouldn't get an
5 unlisted telephone if you believe that Mr. Lin was --
6 A. My -- my new phone number is unlisted.
7 Q. All right.
8 A. I think it is, the one that I've got now is.
9 Q. Did you also accuse Mr. Lin of stalking your
10 wife at a rally?
11 A. I did.
12 Q. Has Mr. Lin ever met your wife?
13 A. No, but he'd never met me either.
14 Q. But it -- you're a prominent on social media; 14:15:00
15 correct?
16 A. That's why he's after me. Yes.
17 Q. All right.
18 Is -- is your wife prominent on social media?
19 A. People know who she is.
20 Q. Is her photograph online?
21 A. Yes.
22 Q. And with her name?
23 A. Yes.
24 Q. Which was the rally that you believe Mr. Lin
25 stalked your wife at? 14:15:31
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1 A. It was a Bernie Sanders rally.
2 Q. In what time frame?
3 A. 2016 -- gosh, I -- I -- I don't know. Between --
4 MR. JACKSON: If you don't know, say so. I don't want
5 you to spend time guessing --
6 THE WITNESS: I don't know.
7 MR. JACKSON: -- or speculating.
8 THE WITNESS: Fair -- fair -- a Sanders' rally in
9 2016.
10 MR. WIENER:
11 Q. What makes you believe he was stalking her?
12 A. It was around the same time that he was outside 14:16:01
13 of my office, stalking me.
14 Q. All right.
15 You testified earlier that you were friends in --
16 this was after February 2016?
17 A. I'm sorry. I was --
18 Q. Do you recall approximately when -- when the
19 rally was?
20 A. Yeah, February -- it was after February 2016.
21 Q. And how many people were at the rally?
22 A. I don't know. 500, 1000, 2000. I don't know.
23 Q. And were you at the rally?
24 A. I was not. 14:16:31
25 Q. Who was at the rally with your wife?
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1 A. I -- my wife went alone. I -- if I remember
2 correctly, I was taking care of the children so that she
3 could go.
4 Q. Do you have any reason to believe that Mr. Lin
5 attended the rally for the purpose of stalking your wife?
6 A. I do.
7 Q. What is that?
8 A. He lives in San Francisco, and he was down here
9 stalking and harassing me at the same time period. So he
10 also must have taken time to stalk and harass my wife as
11 well. 14:17:01
12 Q. All right.
13 You're also aware that Mr. Lin does have a
14 residence in Los Angeles?
15 A. I thought his permanent -- is his permanent
16 residence not in San Francisco?
17 Q. He has two -- two different residences.
18 A. This one's an Airbnb that he doesn't stay at, if
19 I remember correctly.
20 Q. I'm -- I'm not going to testify on his behalf,
21 but --
22 A. His permanent residence is in the Bay Area. He
23 was down here to harass me, and then he used it another
24 time to harass my wife as well.
25 Q. Did he approach your wife at the rally? 14:17:31
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1 A. I don't know.
2 Q. Did he say anything to your wife at the rally?
3 A. I don't think so.
4 Q. Had your wife announced an intention beforehand
5 to attend the rally?
6 A. Yes.
7 THE REPORTER: I'm sorry. Can you repeat that again?
8 MR. WIENER:
9 Q. Had -- had your wife announced an intention
10 beforehand to attend the rally?
11 A. She did.
12 Q. Where did she announce that intention?
13 A. Facebook, I believe.
14 Q. And what specific harassing conduct did Mr. Lin
15 engage in at the rally according to your wife? 14:18:01
16 A. I saw that he was posting that he was there.
17 Q. So he posted that he attended the rally?
18 A. And via social, I was told that he was there as
19 well.
20 Q. Did he approach your wife at the rally?
21 A. I don't believe so.
22 Q. Did he do anything to harass her at the rally?
23 A. In this situation, wouldn't you be a little bit
24 concerned if you were at home with your children, and your 14:18:35
25 wife was with someone that wanted to cause you and your
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1 family harm?
2 Q. Wouldn't you assume that if he was going to
3 stalk her, he would do it at a private place?
4 It -- you said there was --
5 A. That's why we moved.
6 Q. But you said there was somewhere between 500 to a
7 couple of thousand people at the rally.
8 Do you know if there was a police presence at
9 the rally?
10 A. There's police presence at all rallies.
11 MR. JACKSON: So just try to answer the question.
12 THE WITNESS: Yes. 14:19:05
13 Sorry.
14 MR. JACKSON: It's okay.
15 THE WITNESS: Yes, there was police presence at the
16 rally.
17 MR. WIENER: Okay.
18 Q. Is it possible that Mr. Lin attended the rally
19 for some purpose other than harassing your wife?
20 A. Anything's possible, yes.
21 Q. He didn't actually engage in any harassing conduct
22 other than attending a public rally for Bernie Sanders;
23 correct?
25 Q. Is it your understanding that Mr. Lin is a
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1 liberal on politics? 14:19:35
2 A. I did not -- I -- I don't know.
3 Q. Do you know if he's a Republican or Democrat?
4 A. From what I know of him, I know that he's more
5 Democrat than Republican.
6 Q. All right.
7 So it's possible that he attended Bernie Sanders'
8 rally to see Bernie; correct?
9 A. It's possible but not probable.
10 Q. Well, if -- if he wanted to harass your wife,
11 wouldn't he have approached her, assuming --
12 MR. JACKSON: Let's -- Let's not engage in speculation
13 and argue. You guys are just both speculating as to why 14:20:05
14 or why not.
15 You're free to do so, Counsel. I'm just -- it
16 doesn't matter.
17 MR. WIENER:
18 Q. Did you create a ticket special on January 22nd
19 in 2016 for a 2017 event?
20 A. I do so many ticket specials. I -- honest, I
21 just don't know. Sure. 14:20:35
22 Q. All right.
23 Do you recall if around that time frame you were
24 creating a ticket special for Summit Live?
25 A. What time period was this?
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1 Q. January 2016.
2 A. More than likely, yes.
3 Q. All right.
4 And you accused Mr. Lin of having created a
5 LinkedIn similar to yours?
6 A. Oh, yes, yes, yes.
7 Q. Do you know of any law prohibiting Mr. Lin from
8 creating a similar link? 14:21:05
9 MR. JACKSON: Objection. Calls for an expert opinion
10 from a lay witness, calls for a legal conclusion.
11 You can answer the question yes or no.
12 THE WITNESS: I don't know about legal processes.
13 That's why we hire lawyers.
14 MR. WIENER:
15 Q. Did you receive any complaints about the link?
16 A. I did.
17 Q. Who -- who made complaints?
18 A. I don't recall. I don't recall.
19 Q. Do you recall what was the difference between the 14:21:35
20 link that Mr. Lin created and your original link?
21 A. A single capital letter.
22 Q. And how does Bitly work?
23 Typically if I type in a web address, it
24 doesn't -- capitalization doesn't matter, does it?
25 A. On Bitly it does.
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1 Q. All right.
2 A. He was very smart and put a lower case "S" to
3 direct traffic away from the one way that I make money. 14:22:05
4 Q. All right.
5 And did you still proceed to host the
6 Summit?
7 Where was this Summit event?
8 A. I'm sorry. Which?
9 Q. It was for Summit 2017.
10 A. Oh, yeah.
11 The event happened in Los Angeles.
12 Q. What date?
13 A. January --
14 MR. JACKSON: If you recall.
15 THE WITNESS: I don't recall. February 22nd -- ah,
16 February 22nd to the 24th.
17 MR. WIENER:
18 Q. Of 2016 or '17?
19 A. The 2017 event happened February 22nd through 14:22:35
20 24th.
21 MR. WIENER: I -- I'm sorry. Could you read that
22 back?
23 I just want to make sure I was clear.
24 (Record read.)
25 MR. WIENER:
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1 Q. Of 2017?
3 Q. All right.
4 So you were advertising the 2017 Summit Live in
5 early 2016?
6 A. That's correct. That's how conferences are.
7 MR. JACKSON: Your answer -- it's a yes-or-no
8 question. 14:23:05
9 THE WITNESS: Yes.
11 Q. And just to anticipate what your testimony was
12 going to be, you said that typically conferences would be
13 organized -- or ticket sales would begin over a year in
14 advance?
16 Q. Do you know how long Mr. Lin left up the similar
17 link?
18 A. I have no idea.
19 Q. Do you know if it was taken down at any point?
20 A. I do not know if it was taken down.
21 Q. Did you create a different link entirely at some
22 point?
23 A. I don't recall. I don't recall.
24 Q. How did you determine that you lost $8500 in 14:23:35
25 ticket sales as a result of this?
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1 A. Very large amount of ticket sales are sold after
2 the end of the conference when people are most excited.
3 The year prior we sold, I believe, 20,000 in ticket sales
4 right around when we were doing that.
5 It's very common practice for conferences to use 14:24:05
6 the excitement of the event that's going on to sell
7 tickets to the next one.
8 Q. All right.
9 So the ticket sales for -- do you have any
10 documents recording the number of ticket sales for Summit
11 2016?
12 A. Yeah, yes, I do.
13 Q. What -- what was the total attendance for Summit
14 2016?
15 A. Estimated 700 something.
16 Q. And how much was each ticket? 14:24:38
17 A. 2- -- 250 or 299. I -- I don't recall exactly.
18 Q. And how many people attended Summit 2017?
19 A. 600 -- 650.
20 Q. And do you recall what the ticket price was?
21 A. 250. 14:25:09
22 Q. Do you know if any of the persons were repeat
23 attenders?
24 A. You know, I -- I do not know that.
25 Q. So your estimate of $8500 lost was based on the
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1 difference in attendance between Summit 2016 and Summit
2 2017? 14:25:39
3 A. No.
4 Q. And how -- how did you come at the number of
5 $8500?
6 A. How many we usually sell during that -- that time
7 frame, the dates that Mr. Lin put up the Bitly link.
8 Q. You testified earlier, though, that you weren't
9 sure what dates the Bitly link was put up by Mr. Lin.
10 A. I didn't know when they were taken down.
11 Q. But what date was it put up?
12 A. Basically right when I put up the special. I 14:26:09
13 remember that. I don't -- I'm like -- I'm really bad with
14 dates, so --
15 Q. Have you -- you're claiming mental and emotional
16 distress and physical suffering as a result of Mr. Lin's
17 actions?
18 A. Yes.
19 Q. What type of mental or emotional distress? 14:26:39
20 A. It's very stressful having somebody harassing
21 you, calling your phone, having to remember to turn off
22 your phone every time you go to bed, especially when you
23 have small children and you might be out of town.
24 Q. Have -- have you sought any treatment for --
25 would you describe it as general anxiety, depression?
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1 Have you consulted with a mental health 14:27:10
2 practitioner about it?
3 A. I unfortunately have not, no.
4 Q. Have you had any actual physical pain?
5 A. Well, my dentist -- I've been grinding my teeth
6 which I've never done. I don't sleep. It's just been a
7 very hard ordeal.
8 Q. Is there a condition associated with grinding
9 your teeth or -- 14:27:42
10 A. Stress -- I think it's a mixture of stress and
11 anger.
12 Q. All right.
13 I'm just wondering if there was a medical term
14 for it. I was thinking if you have the TKJ.
15 What is it?
16 MR. JACKSON: Oh, TMJ?
17 MR. WIENER: TMJ.
18 THE WITNESS: No. It's just stress.
19 MR. WIENER:
20 Q. Have you had any dental work done as a result?
21 A. I'm going to have to. I am, truly.
22 Q. What is the name of your dentist?
23 A. Dr. E. Guerra, G-U-E-R-R-A. 14:28:15
24 I'm going to go see a periodontist. I'm 40 years
25 old. It sucks. I don't want the stress.
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1 Q. Have you been prescribed any medications or
2 treatments?
3 A. I have not.
4 Q. Has Mr. Lin ever made any effort to contact your
5 children? 14:28:48
6 A. No.
7 Q. All right.
8 And they've not suffered any emotional distress
9 as a result of anything he's done or not done?
10 MR. JACKSON: They're not part of the case.
12 MR. JACKSON: I'll stipulate to that.
13 MR. WIENER:
14 Q. Has your wife had any symptomology different than
15 what you described?
16 Has she had any emotional distress as a result of
17 Mr. Lin?
18 A. She keeps a butcher knife at the front door.
19 THE REPORTER: Keeps a what? 14:29:18
20 THE WITNESS: Butcher knife.
21 MR. WIENER:
22 Q. It's correct that Mr. Lin's never tried to come
23 into your personal residence, though, at any time?
24 A. We moved.
25 Q. Prior to your moving, did he ever try coming to
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1 your personal residence?
2 A. No, but when he was outside of my office, I
3 realized that he didn't know boundaries or understand
4 respect for other people.
5 Q. And what was the circumstance where he came 14:29:48
6 outside your office?
7 A. Celebrating that he was back in America,
8 apparently.
9 MR. WIENER: Why don't we take a five-minute break?
10 MR. JACKSON: Sure.
11 MR. WIENER: I'm probably pretty close to done.
12 MR. JACKSON: Sure. Let's do it. 14:30:18
13 THE VIDEOGRAPHER: We're going off the record. The
14 time is 2:30 p.m.
15 (Recess taken.)
17 2:41 p.m. 14:40:52
18 MR. WIENER:
19 Q. On your interrogatory responses, you listed Lizza
20 Morales and Lynette Bell as witnesses.
21 We've discussed them already, but who is Hannah
22 Breaux?
23 A. An influencer in Austin, Texas.
24 She runs a dog-grooming and dog sitting
25 services --
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1 Q. All right.
2 A. -- this young lady.
3 Q. What's her connection with Mr. Lin?
4 A. Just has been affected by him being around, 14:41:22
5 trolling her, and she reached out saying that she wanted
6 to help if needed be.
7 Q. And how did Mr. Lin allegedly troll her?
8 A. I don't recall. It's been so many stories.
9 Q. All right.
10 Who is Carrie Long?
11 A. Carrie Long is -- Carrie -- her -- her -- her
12 maiden name is Carrie Emerick, an influencer on Periscope. 14:41:52
13 Q. And what is Mr. Lin's connection with her?
14 A. Similar feeling of harassment from her as well,
15 if I remember correctly.
16 Q. And who is Sherry Madison O'Connor?
17 A. Two women that helped worked social. Two of our
18 volunteers at Summit Live. 14:42:22
19 Q. And what was their connection with Mr. Lin, if
20 any?
21 A. Similar. Just had to deal with some of his
22 inappropriate comments.
23 Q. All right.
24 Who is Alex Yang?
25 A. Alex Yang, he is a tech blogger in New York.
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1 Q. Did he write any articles about Summit or 14:42:52
2 Periscope?
3 A. I'm sure he did. He -- he writes a lot of tech
4 focus articles. I can't recall which ones.
5 Q. All right.
6 Did you have any conversations with him about
7 Mike Lin?
9 Q. You'd mentioned that you had formed a nonprofit
10 called Zero Moderation?
11 A. I did. 14:43:22
12 THE REPORTER: Called what?
13 MR. WIENER: Zero Moderation.
14 Q. But was that actually a corporation?
15 A. And it was only done on social media. It was
16 never incorporated, turned into an LLC or anything.
17 MR. JACKSON: So is your answer no?
18 THE WITNESS: No.
19 MR. WIENER:
20 Q. Do you know if it ever qualified for a 501(c)(3)
21 status under the IRS Code?
22 A. No.
23 Q. All right.
24 So what made you say that it was a nonprofit?
25 A. Because I never took any profit.
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1 It -- we wanted to make it something -- into
2 something. 14:43:52
3 Q. Are -- are there any other -- or is there any
4 other harassing conduct that you believe Mr. Lin engaged
5 in towards you or your family that we did not discuss
6 today? 14:44:22
7 A. I feel like we covered it, phone calls, e-mails,
8 showing up outside my area of work, being where my wife
9 is.
10 Q. All right.
11 And when he showed up outside your work, that was
12 a one-time occasion?
14 And yes, he did livestream it, talking directly
15 about my name and everything, yes.
16 Q. Do you have any recordings of that livestream?
17 A. Oh, yeah, I believe I do.
18 Q. All right.
19 Can I ask that you produce those? 14:44:52
20 MR. JACKSON: Mike, let's -- let's do a formal --
21 let's do a formal production inspection demand and/or you
22 and I will stipulate off the record. We're not going to
23 agree to anything on the record.
24 MR. WIENER: Right.
25 I mean, I believe it's covered in our prior
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1 demands, but I can serve a supplemental demand, but that's
2 fine.
3 MR. JACKSON: Yeah, let's just talk once the
4 deposition is done.
6 Q. And then you said that one of the purposes of
7 posting the livestream video of Mr. Lin in February 2016
8 was to cause Mr. Lin to seek mental health treatment; is 14:45:22
9 that correct?
10 A. I've told Mike on multiple occasions that he
11 needed to get off of social and get help.
12 Q. How was that video -- or how was that livestream
13 intended to accomplish that?
14 MR. JACKSON: Objection. It's asked and answered.
15 We've covered this already. You can answer the question
16 again.
17 MR. WIENER:
18 Q. Do you have an explanation as to how that
19 livestream was supposed to cause Mr. Lin to seek mental 14:45:57
20 health treatment?
21 A. I -- I would like to see him be off of social.
22 If there's any way for me to help -- tell him directly or
23 indirectly to get off of social and live life, I'd like to
24 do that.
25 Q. All right.
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1 So the purpose of the video was to get him off of
2 social media, and you -- you believe that that would
3 improve his mental health? 14:46:30
4 A. I believe that if Mike -- yes.
5 Q. How do you believe that social media is adversely
6 affecting his mental health?
7 A. It's not connected -- not connecting him to
8 reality with real interpersonal relationships with family
9 or actual friends.
10 Q. All right. 14:47:00
11 It's correct that you're a large influencer in
12 the social media realm as well, though?
13 A. Yes, and my friends offline are the ones that
14 matter. On social media, it's not -- it's not that way.
15 Q. All right.
16 So you believed Mr. Lin would do better to focus
17 on his offline relationships rather than social media?
18 A. I think we all would.
19 MR. WIENER: All right. Thank you. 14:47:30
20 I have nothing further, and I'll -- I'll propose
21 the same stipulation with respect to the deposition
22 transcript. You -- you have 45 days to review it and so
23 on. It's a slightly different practice in L.A. So I'd
24 rather just adopt your stipulation.
25 MR. JACKSON: Sure. So stipulated. We'll just
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1 incorporate the prior stipulation.
3 THE VIDEOGRAPHER: That concludes today's deposition.
4 We're now going off the record. The time is 2:48 p.m. 14:48:00
5 (By instruction of counsel, the reporter has
6 redacted the following stipulation from the deposition of
7 Michael James Lin, taken this same date, as reproduced
8 below:
9 MR. JACKSON: Okay.
10 So what I'd like to do is I'd like to propose a
11 stipulation that the original court reporter be relieved
12 of her responsibilities under the Code of Civil Procedure;
13 That the original deposition transcript be sent
14 directly to plaintiff's counsel. That he has 45 days from
15 receipt within which to coordinate the review and
16 correction and signing of the original deposition
17 transcript;
18 That any changes, corrections or modifications to
19 the original deposition transcript be communicated to my
20 office in writing within that 45-day period of time;
21 That if I'm not advised as to any changes,
22 corrections or modifications -- and that the original
23 deposition transcript is signed under oath -- then an
24 unsigned certified copy of the original deposition
25 transcript may be used for all purposes in this matter,
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1 including at time of trial, and I think that's about it.
2 MR. WIENER: Sure.
3 And I'll be happy to propose a reciprocal
4 proposal with regard to the transcript from Mr. Bell's
5 deposition.
6 MR. JACKSON: And you'll make the original deposition
7 transcript available for all hearings, proceedings and
8 trial without notice.
9 MR. WIENER: Yes.
10 MR. JACKSON: Just bring it with you.
11 MR. WIENER: Sure.
12 MR. JACKSON: Okay. So stipulated. All right.
13 THE REPORTER: Do you need a copy of this one?
14 MR. WIENER: Yes, I do.)
15 (Deposition Exhibit 1 was marked for
16 identification by the Certified Shorthand Reporter and are
17 attached hereto.)
18 (Deposition proceedings concluded at 2:48 p.m.
19 Declaration under penalty of perjury on the following page
20 hereof.)
21
22
23
24
25
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1 I do solemnly declare under penalty of
2 perjury, under the laws of the State of California,
3 that the foregoing is my deposition under oath; that
4 these are the questions asked of me and my answers
5 thereto; that I have read same and have made the
6 necessary corrections, additions, or changes to my
7 answers that I deem necessary.
8 In witness thereof, I hereby subscribe my
9 name this ______ day of __________________, 20____.
10
11
12
13
14
15 ________________________________
16 RYAN ANDERSON BELL
17
18
19
20
21
22
23
24
25
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1 CERTIFICATION
2 OF
3 CERTIFIED SHORTHAND REPORTER
4
5 I, the undersigned, a Certified Shorthand
6 Reporter of the State of California do hereby certify:
7 That the foregoing proceedings were taken
8 before me at the time and place herein set forth;
9 that any witnesses in the foregoing proceedings, prior
10 to testifying, were placed under oath; that a verbatim
11 record of the proceedings was made by me using machine
12 shorthand which was thereafter transcribed under my
13 direction; further, that the foregoing is an accurate
14 transcription thereof.
15 I further certify that I am neither
16 financially interested in the action nor a relative or
17 employee of any attorney of any of the parties.
18 IN WITNESS WHEREOF, I have this date
19 subscribed my name.
20 Dated: 5/8/17
21
22
23 <%signature%>
24 Robin L. Bittel, CP, RPR
25 CSR No. 6419
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[& - advertising]
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[concerned - describes]
concerned 64:24 conviction 15:7 created 13:25 decide 15:1,1

concerning 34:5 convictions 15:12 14:18 17:20 18:6 31:13
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description 4:10 door 73:18 engaged 77:4 expert 67:9

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investigating
jacksonwilson.c... 57:15 58:1 59:21 likewise 19:7
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[limited - misdemeanors]
limited 16:11 link 50:15 67:8,15 longer 38:18 matter 8:23 66:16
lin 1:4 2:4 3:3,23 67:20,20 69:17,21 look 24:16 26:14 67:24 79:14 80:25
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mitch 3:20 5:16 n 58:8 59:14 81:12

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[pain - production]
pain 72:4 permanent 63:15 police 51:6,7 54:2 prevent 6:23

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866 299-5127
[professional - related]
professional 1:21 48:1 49:13 51:20 realm 79:12 23:1,2 24:23 25:4
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866 299-5127
[relating - sex]
relating 56:21 reside 9:3,9 52:5 53:22 56:7 santa 9:4,7 54:8
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[sexbot - tag]
sexbot 42:22 49:4 50:17,22 speculation 27:25 stories 75:8

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866 299-5127
[taiwan - two]
taiwan 45:24 46:3 thank 8:4 30:19 70:16,20 transcript 4:12

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Transcription of Videotaped Deposition of Ryan Anderson Bell

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Transcription of Videotaped Deposition of Ryan Anderson Bell

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1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 COUNTY OF LOS ANGELES

Veritext Legal Solutions

Veritext Legal Solutions

Veritext Legal Solutions

4 RYAN ANDERSON BELL

5 Examination by: PAGE

10 NUMBER DESCRIPTION PAGE

12 Exhibit 1 Transcript of a YouTube video 24

13 posted by Ryan Bell on or about

14 February 11 or 12, 2016

17 WITNESS REFUSES NOT TO ANSWER

Veritext Legal Solutions

2 Monday, April 24, 2017, 12:55 p.m. - 2:48 p.m.

4 THE VIDEOGRAPHER: Good afternoon. We're on the

5 record at 12:55 p.m. on April 24th, 2017. This is the

6 video-recorded deposition of Ryan Bell.

7 My name is David Bradley, here with our court

8 reporter, Robin Bittel. We are here from Veritext Legal

9 Solutions at the request of counsel for Plaintiff. This

10 deposition is being held at 20 Corporate Park in Irvine,

11 California. The caption of this case is Lin versus

13 Will everyone present please introduce

14 themselves, starting with the witness?

15 THE WITNESS: Ryan Bell.

16 MR. JACKSON: Mitch Jackson, counsel for Mr. Bell,

17 both on the answer to the complaint and on the first

19 MR. WIENER: And I'm Seth Wiener. I'm the attorney

20 for Plaintiff and Cross-Defendant Mike Lin.

21 MR. LIN: Mike Lin, plaintiff.

22 THE VIDEOGRAPHER: And will the court reporter please

23 swear in the witness? 12:56:30

Veritext Legal Solutions

2 a Defendant and Cross-Complainant herein, called as a

3 witness by and on behalf of the Plaintiff and

4 Cross-Defendant, and having been first duly sworn by the

5 Certified Shorthand Reporter, was examined and testified

12 Mr. Bell, did you hear the admonitions that your

13 attorney provided to Mr. Lin earlier about deposition

17 And do you understand those admonitions?

20 And I'll -- I'll just incorporate them by

22 Are you under any medication or substance that

23 would prevent you from giving accurate testimony today?

25 Q. Is there any other reason why you can't go forward

Veritext Legal Solutions

4 Could you state your full legal name for the

6 A. Ryan Anderson Bell.

7 Q. And do you go by any other names online?

9 Q. And what is your date of birth?

11 Q. And where were you born?

14 And what is your spouse's name? 12:57:30

16 THE REPORTER: Can you spell that, please?

17 THE WITNESS: L-Y-N-E-T-T-E.

19 Q. And what date were you married?

20 A. August -- I always mix up my kids' birthdays with

21 our -- August 22nd, 2013.

23 And do you have any children? 12:58:00

25 Q. And how old are they?

Veritext Legal Solutions

3 I'm not going to ask their names.

4 A. Thank you so much.

5 Q. How do you know your attorney, Mitch Jackson?

6 A. Through live video, actually.