littleroundman, could you possibly be insinuating the IQ's of them thar termites might be a few points higher than anyone that still believes the bloated pile of excrement flushed their way by Sir Gasbag and Frank "the BANK" McCrady?
littleroundman, could you possibly be insinuating the IQ's of them thar termites might be a few points higher than anyone that still believes the bloated pile of excrement flushed their way by Sir Gasbag and Frank "the BANK" McCrady?
Last edited by pantherdadX2; 08-21-2012 at 12:50 AM.
perZACKLY right
The only thing necessary for the triumph of evil is for good men to do nothing
Let's take a look at what Don Holbrook said:
Reality Based OptimistWhen we see the financing secured and dirt is moving we will believe Earthquest is really coming. Numerous groundbreaking dates have come and gone. Holbrook has been one of the ones proclaiming these fictitious dates. He told Pahrump the new developer, Contour, is buying (present progressive tense) the property in the summer of 2011. He then boldly proclaimed ground would break in Decemebr 2011 or the first quarter of 2012. All fiction and likely a ruse to get in the door there.says:
May 15, 2012 at 11:24 am
Again, all of your statements are factually incorrect. I agree completely with Dr. Waters. Your assessment that EarthQuest is dead is incorrect. In fact, Earthquest has a new developer with a new and better development agreement that is when the funding is finalized going to make the tax payers of EMCID 100% whole.
The land had to be purchased from the bankruptcy court in order to allow the new developer the right to secure a purchase agreement for the land that he needs for the EarthQuest project.
In addition, if it had not been for the visionary actions of EMCID to intercede with the BK process and secure these rights for the land purchase and secure a new developer the project would have died with the failed original developer.
EMCID's Frank McCrady did nothing visionary. At this point the shyster failed developers, who didn't pay what they promised, are the only ones who can repurchase the Earthquest property. How stupid is that? Of course, Friendswood is laughing. They already announced their intention to build homes on the property when the option to purchase it isn't exercised in the next 18 months.
Holbrook has claimed he advised EMCID against using the failed developers Marlin Atlantis, but interestingly, he had no problem working for them and accepting hundreds of thousands in payments from them while simultaneously working for EMCID, the charity and bringing in armies of his fundraising and other professional services buddies. Holbrook had his hands in numerous pies.All of this was factually explained to the town board prior to any vote on their own desire to consider the development of a major destination attraction for Pahrump. We have never proposed a theme park. In addition, my role in all of these projects is to give advice on what incentives can or should be considered to attract the private sector investment necessary to fund the construction of such projects. I do not do my opinions based on the success of projects getting funded or upon the success of the developer hired by the public sector. My job is to create a recommendation for how to best engage the public-private partnership. That does not mean that all my clients adhere to my advice. EarthQuest is going through a transition from the failed developer to a new developer… many projects during the greatest financial crisis of my lifetime have had to do the same types of mitigation. That does not mean the project has failed.
Truth, facts and opinion are not actionable. Holbrook's frivolous suit is drowning him in negative publicity and exposing lots of information he would much rahter had not been dug up and splashed everywhere on the internet. My postings routinely go viral and top the search results!In addition, the statements and libelous comments made by Heather Dobrott and Mr. Frank Maurizio were not constructive and were not valid… they were misrepresentations on purpose in order to harm my professional reputation and thus illegal. Those types of comments are not protected by the first amendment.
Holbrook is clearly delusional and having conspiracy theory fantasies filling his pitiful little mind. There was a ton of information on the internet in 2011 before Huber Heights signed the contract. Holbrook was fired by Red Wing and Wayne County. His reputation couldn't have been made worse than it already was. Holbrook really started getting skewered after he started threatening everyone on the planet that dared discuss Earthquest and Pahrump (matters of public concern / where tax dollars are being spent) which happened after Huber Heights had shown him the door.With regard to Huber Heights I am counter suing them for breach of contract as they have no basis for their claims and they are using these tactics to avoid paying their legitimately owed bill for our final product and have taken our intellectual property without paying for it. Therefore we are going to deny any validity to all their claims and sue them for damages. I know why they made such an unprofessional breach of their contract and it will come out in court just what was actually behind this very poor business decision on the City of Huber Heights part, and it had nothing to do with my professional work product and nothing to do with any of their allegations.
Earthquest created no jobs except for Holbrook getting his 1.2 million + and his buddies getting hired for various a sundry things. The people of Texas have nothing to show for it but 21 million in bond money that must be satisfied. Certainly, with this apparent failure there is reason for Pahrump to appraoch Holbrook cooked up plans with extreme caution.The people of Pahrump are in need of more jobs and building additional tourism is a very successful method to achieve those goals that the town board has for their constituents. But in the end, I am not the developer and I am not the financier. I am a public-policy specialist that has given them my opinion on the economic development issues that need to be addressed if they choose to move forward and create jobs and build additional economic benefits for their residents.
Holbrook is a self-created monster. His hideous attacks on taxpayers on the Pahrump Valley Times, Houston Press, Kingwood Underground and more tell the story. He viciously went after taxpayers in pahrump who were not supporting his destination theme park crap. He then attacked everyone who dared to speak out and threatened to sue all those who commented. He has since filed said frivolous harassment suit. I intend to see the whole world is well aware of Holbrook's lies and treachery. I will fight to the death to preserve the right to free speech!In addition, Mr. Maurizio has stated falsely that our report to the Town of Pahrump was lifted from the EarthQuest project and that is a complete false statement and a accusation of dishonesty. Perhaps he should have taken my letter of warning I sent him more seriously. He should have been legally counseled on the damages of calling someone a liar and dishonest business person are when you do so intentionally and with the intent to harm someone’s reputation and economic livelihood with malice and specific purpose. I took the high road and sent both of these libelous bloggers warnings, both of which ignored them and choose to purposefully continue to spew misinformation, resorted to name calling, creating a negative image of my persona and professional work product and even attacked my reputation with my industry association colleagues and my social affiliations with allegations. That does not sound like the methodology or decision making process of what most of us would consider appropriate actions. If other people had experienced this type of hatred online that has been directed at me and my family and now my clients, they would more than likely have taken the same appropriate actions as I have done.
From Holbrook's bankruptcy:Your portrayal of my reorganization bankruptcy was completely not factual as well. You obviously have no idea how such business matters work. My BK was a reorganization because I got stiffed for my final payment by Earthquest, which I was told was forthcoming by the developer. I made the decision to pay my IRS tax bill with that payment and when it did not come I could not mitigate the tax ramifications and workout a payment with the IRS unless I was under this Chapter 11 reorganization plan. There is nothing deceitful about creating a repayment plan that I could adhere to with my income that was available to me and predictable. My speaking, books and consulting projects are not predictable. Therefore the only longterm retainer for work I was able to use was the work I was contracted to do for EMCID. That does not mean that I did not disclose all of my income appropriately as you have stated. You again are factually wrong. Please leave me, my family and my clients alone. People who get online and spew such hatred are in my opinion mentally off and socially unbalanced. In my opinion Heather Dobrott and Frank Maurizio have some type of anger issues that they themselves need to deal with and quit blaming your hatred for your own lives on others. I am sure you have enough problems of your own or shortly will have in my opinion.
1
INTERNAL REVENUE SERVICE
110 CITY PARKWAY
LAS VEGAS NEVADA 89101
INTERNAL REVENUE SERVICE
P.O. BOX 21126
PHILADELPHIA PA 19114-0326
Phone: INCOME TAX $ 113,500.00
2
INTERNAL REVENUE SERVICE
OGDEN UTAH 84201-0030
INTERNAL REVENUE SERVICE
OGDEN UTAH 84201-0030
Phone: INCOME TAX $ 28,400.00
5
INTERNAL REVENUE SERVICE
P.O. BOX 7346
PHILADELPHIA PA 19101-7346
INTERNAL REVENUE SERVICE
P.O. BOX 7346
PHILADELPHIA PA 19101-7346
Phone: INCOME TAX $ 6,300.00EarthQuest 2009 bond sale: where did tax dollars go - Monday, April 30, 2012 - Copyright 2007 Ourtribune.com1. Income from employment or operation of business
State the gross amount of income the debtor has received from employment, trade, or profession, or from operation of the debtor's business, including
part-time activities either as an employee or in independent trade or business, from the beginning of this calendar year to the date this case was
commenced. State also the gross amounts received during the two years immediately preceding this calendar year. (A debtor that maintains, or has
maintained, financial records on the basis of a fiscal rather than a calendar year may report fiscal year income. Identify the beginning and ending dates of
the debtor's fiscal year.) If a joint petition is filed, state income for each spouse separately. (Married debtors filing under chapter 12 or chapter 13 must
state income of both spouses whether or not a joint petition is filed, unless the spouses are separated and a joint petition is not filed.)
None
AMOUNT SOURCE
Year to date: $74,997.00 East Montgomery County Improvement Distric
Last Year: $99,996.00 EMCID
Year before: $90,000.00
So that equates to:
$90,000.00 for 2009
$99,996.00 for 2010
$74,997.00 for 2011 up to the filing date????
__________________________________________
Holbrook's taxes are a whopping $148,200. So, he was expecting some hefty payments from the Earthquest project to completely satisfy those. Think about the hundreds of thousands he was raking in from the tax dollars of everyday families struggling to make ends meet. Sickening! And, think about what that buffoon has admitted in his angry rant and bankruptcy filings. Holbrook admitted his books, speaking engagements and consulting projects make him little and were unpredictable. He was making his living off of Earthquest since 2007. Even though he made over 1.2 million from Earthquest, he claimed incomes of less than $100,000 per year to the IRS. I still want to know how a guy could be claiming $90,000 in income in 2009 when the hundreds of thousands in bond money landed in his lap. How does a guy making $90,000.00 afford a private school that is $20,000.00 a year for his high school aged son and tour Europe that summer? Holbrook has sure lived the life of a king on the taxpayers dime!!!EarthQuest 2009 bond sale: where did tax dollars go……
Third, Don Holbrook, consultant, was paid an eye-popping $773,963.43 out of the bond proceeds. Holbrook is truly a consultant extraordinaire, capable of walking on both sides of one street at the same time. That is, despite the obvious conflict of interests, he represented both EMCID and the Developer Group as their respective consultants on EarthQuest.
In an email dated April 18, 2012, McCrady acknowledged to The Tribune that EMCID had retained, and paid Holbrook, as its consultant, the sums of $27,000 and $277,000. Out of the 2009 bond proceeds, Holbrook was paid $273,963.43 by EMCID for work on tax incentive and legislative matters. EMCID subsequently paid him an additional $500,000 (as the Developer’s consultant) as a finder’s fee for the EarthQuest site.
Consequently, Holbrook has been paid more than $800,000 by EMCID, presuming the $277,000 and the $273,963.43 mentioned above refer to the same fee. Furthermore, while Holbrook was carting off EMCID’s bank vault, he and his merry band of minions were also plundering the EarthQuest Institute for every dime it had received. Under the auspices of EMCID, Holbrook alone stripped out at least $328,255.00 from the Institute. (For details, see The Tribune article dated April 4, 2012). Altogether, it appears that Holbrook received, from EMCID and the Institute, upwards o $1,200,000 for his various, if not nefarious, EarthQuest activities.
The level of compensation paid to Holbrook is beyond any rational explanation, let alone comprehension. What possible justification can the EMCID leadership and board make to its constituents that Holbrook was deserving of these unwarranted, outrageous, indeed, unbelievable sums of money?
Soapboxmom
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
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Sickening.....Could any one word describe this whole scenario better? .....I don't think so. That one word has hit the nail on the head., SBM,....repeatedly. Makest Jesus vomit.....MEthinks so. Leave me and my family alone?. Holbrook?....MEthinks not! Unfortunately for your family, Mr. Holbrook, your actions as head of your household have consequences on them, my friend. Your actions in trying to silence anyone's opinions on how taxpayer's money is spent, in my opinion. was a very ignorant move on your part. My advice to you, Mr. Holbrook, if you feel so strongly about silencing people's opinions on public matters, is to pack you and your family's bags, get out of the United States of America and move to China, Noth Korea, Cuba, or Iran and work on projects there that use public money without citizens input, GOD BLESS THE USA!!!!!.....and TEXAS!!!!!
WHAT ??Originally Posted by Donny
Is Mr Holbrook psychic now ??
How THE H**L does he know the motives of his critics ??
With serial behaviour such as his, there's a myriad of possible reasons people should choose to not simply lay down and take being done over.
As for "harming his reputation" perhaps a mirror would be a better place to start looking before pointing the finger at others.
The only thing necessary for the triumph of evil is for good men to do nothing
Don Holbrook's son is again attending the exclusive prep school, The Meadows. How does he afford that when he is in bankruptcy again and cannot pay his taxes or creditors???
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Breaking News!!!!
Don Allen Holbrook's frivolous harassment case is imploding. My delightful co-defendant's, The Houston Press and Craig Malisow, hadn't even responded to the lawsuit yet and they have been dismissed!!! Holbrook's attorney, Sue Seeberger, had agreed with the Houston Press and Craig Malisow's attorney to extend the time for their responses to August 30, 2012. So, the paper and its finest reporter had not even answered yet and they are out. In fact, Seeberger just two days ago was still chasing my good man Craig around trying to serve him. Don Holbrook now looks like a total fool. Hilarious!!!!IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
CIVIL DIVISION
CITY OF HUBER HEIGHTS, OHIO
Plaintiff,
v.
DON ALLEN HOLBROOK, LLC
Defendant/Third-Party Plaintiff
v.
Heather Dobrott, et al.,
Third-Party Defendants.
CASE NO. 2012-CV-02947
JUDGE MICHAEL TUCKER
NOTICE OF DISMISSAL WITHOUT
PREJUDICE OF THIRD-PARTY
DEFENDANTS THE HOUSTON
PRESS, THE HOUSTON PRESS D/B/A
VILLAGE VOICE MEDIA HOLDINGS,
LLC D/B/A HOUSTON PRESS, LP
D/B/A BACKPAGE.COM, LLC, AND
CRAIG MALISOW
Pursuant to Ohio R. Civ. P. 41(A)(1)(a), and Mont. Co. C. P. R. 2.15(I)(A), Defendant
and Third-Party Plaintiff Don Allen Holbrook, LLC gives notice that it dismisses, without
prejudice, its claims against Third-Party Defendants The Houston Press, The Houston Press d/b/a
Village Voice Media Holdings, LLC d/b/a Houston Press, LP d/b/a Backpage.com, LLC, and
Craig Malisow in the above-referenced matter.
Respectfully Submitted,
s/Sue Seeberger
Sue Seeberger (0059730)
5975 Kentshire Drive, Suite D
Dayton, Ohio 45440-4264
Voice: (937) 291-8646
Fax: (937) 291-8650
sueseeberger@biegeltye.com
Attorney for Defendant Don Allen
Holbrook, LLC
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
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ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Thursday, August 23, 2012 4:30:35 PM
CASE NUMBER: 2012 CV 02947 Docket ID: 17461522
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO2
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
GENERAL DIVSION
CITY OF HUBER HEIGHTS, OHIO.
Plaintiff,
v.
DON ALLEN HOLBROOK, LLC
Defendant /
Third-Party Plaintiff,
v.
HEATHER DOBROTT, et al.
Third-Party Defendants
)
)
CASE NO: 2012-CV-02947
JUDGE MICHAEL TUCKER
Third-Party Defendants
Heather Dobrott, Cynthia Calvert,
and Hartburg Publications, LLC’s
Joint Reply Brief in Support of Their
Motions To Dismiss for
Lack of Personal Jurisdiction and
Motions to Quash Service of Process
Third-Party Defendants Heather Dobrott, Cynthia Calvert, and Hartburg Publications, LLC’s respectfully renew their request that this matter be dismissed for lack of personal jurisdiction.
Defendant / Third-Party Plaintiff Don Allen Holbrook, LLC’s Responses in
Opposition to have no merit for two reasons:
Holbrook fails to make a prima facie evidentiary showing that Dobrott, Calvert, or Hartburg’s publications “caus[ed] tortious injury…in this state,” which is a necessary requirement to confer personal jurisdiction under Ohio’s long-arm statute; and Holbrook fails to make a prima facie showing that Dobrott, Calvert, or Hartburg purposefully availed themselves of Ohio’s laws, which is a necessary requirement under the Due Process Clause of the United States Constitution.
For these reasons, Dobrott, Calvert, and Hartburg respectfully request this Court to dismiss Holbrook’s claims against them for lack of personal jurisdiction and improper service of process.
A. THERE IS NO JURISDICTION UNDER OHIO’S LONG-ARM STATUTE—THERE IS NO EVIDENCE THAT DOBROTT, CALVERT, AND HARTBURG CAUSED A TORTIOUS INJURY IN OHIO.
i. Holbrook has not presented any evidence or made a prima facie case supporting its claim for jurisdiction.
It is undisputed that Ohio’s long-arm statute requires Holbrook to show that Dobrott, Calvert, and Hartburg “caused] tortious injury…in this state” in order to prove personal jurisdiction over these out-of-state defendants. R.C. 2307.382(A). Holbrook has the burden of establishing the Court's jurisdiction. Kerger v. Dentsply Int'l, Inc., 8th Dist. No. 94430, 2011-
Ohio-84, ¶11. Holbrook must make a prima facie evidentiary showing of jurisdiction to withstand the motion to dismiss—an evidentiary showing sufficient to convince reasonable minds that this Court has jurisdiction. Id. (citing Giachetti v. Holmes, 14 Ohio App.3d 306, 471
N.E.2d 165 (1984) and Klug v. Trivison, 137 Ohio App.3d 838, 739 N.E.2d 1243 (2000)).
It is Holbrook’s burden, therefore, to come forward with sufficient evidence to make a prima facie showing of causation. He has not done so. Instead, he has provided this Court with abject speculation built upon hearsay. Holbrook has only provided inadmissible hearsay statements that Huber Heights representatives received a “strange” telephone call and had
researched information on the internet about him. He hopes that this Court will speculate, as he has, that the telephone call and the articles came from Dobrott, Calvert, or Hartburg and further speculate, as he has, that these statements caused Huber Heights to end its business
relationship with him. This Court cannot and should not hale three Texas residents to Ohio to participate in litigation built upon speculations based solely on hearsay.3
ii. There is no evidence that anyone in Ohio read anything published by Dobrott, Calvert, and Hartburg before Huber Heights ended its business relationship with Holbrook. Holbrook contends that its alleged injuries occurred on February 29, 2012. Def’s 2d Am. Third-Party Complaint, June 22, 2012, ¶12. Yet, there is no evidence or even an allegation
that anyone in Ohio had ever read the articles by Dobrott, Calvert, and Hartburg before February 29, 2012. Even Holbrook himself admits he was ignorant of these publications until after March 14, 2012. See Holbrook Aff. ¶6-9.
Holbrook’s responses to Dobrott’s and Calvert’s motions include affidavits from three individuals: Shelli Nestle, Roger Reynolds, and Steven Carne. All three affiants claimed that they accessed Dobrott’s publications on the internet. Conspicuously absent, however, is any testimony suggesting that the affiants—or anyone else in the State of Ohio—viewed Dobrott’s
publications before February 29, 2012. The closest Holbrook comes to establishing this essential part of its prima facie case is the following statement in Carne’s affidavit: I spoke to Mayor Fisher on March 15, 2012 and Mayor Fisher told me that Jim Borland, Acting City Manager…gave [Council Member Mark] Campbell copies of internet research on Don Allen Holbrook and that Mr. Campbell gave copies to Mr. Fisher.
Carne Aff., ¶6. Of course, Carne’s statement about what Mayor Fisher told him is pure hearsay and is not admissible evidence. But even if this Court were willing to consider the statement, there is no evidence that this alleged “internet research” included any publication by Calvert,
Dobrott, or Hartburg. Moreover, it fails to identify (among other things): the date on which the “internet research” was performed; the date on which the documents were provided to Council Member Campbell; a description of the documents that were included in the “copies” that were
provided to Council Member Campbell; or any description of any action taken by anyone in response to this “internet research.”4
Holbrook’s response to Calvert and Hartburg’s motion to dismiss was also supported by an affidavit of Don Allen Holbrook.
1
Therein, he claims:
On February 29, 2012, I received an e-mail from Gary Adams, City Manager at
the time, in which Mr. Adams told me that he had been contacted by a reporter in a city near Houston, Texas asking if the city had a contract with [Holbrook],
which Mr. Adams said he confirmed, and then Mr. Adams told me in the e-mail
that it was a “strange conversation”, but that he was not concerned about it
because it did not pertain to the City.
Holbrook Aff. ¶3. Holbrook’s statement about what Gary Adams said is also inadmissible hearsay, and Holbrook’s statement about what Adams said that an unidentified reporter said is inadmissible double hearsay. Once again, however, even if this Court were willing to consider this testimony, it does not identify the name of the reporter or the substance of the conversation.
If anything, this statement exonerates Dobrott, Calvert, and Hartburg because, by Holbrook’s own admission, the “strange conversation . . . did not pertain to the City.” Finally, Holbrook offers no support for its suggestion that this Court must accept the conclusory allegations in its pleadings as true. Holbrook alleges that Huber Heights ended its business relationship with him as a result of publications by Dobrott, Calvert, and/or Hartburg.
But he has provided not a scintilla of actual evidence that anyone in Ohio read any publications before February 29, 2012. Because Holbrook has no evidence to support its allegations that Dobrott, Calvert, or Hartburg “caus[ed] tortious injury…in this state,” on or before that date, he has not made a prima facie showing that the Ohio long-arm statute can establish personal
jurisdiction over them. Accordingly, this Court should grant the motion to dismiss.
1
Nestle, Reynolds, and Crain’s affidavits were also attached to Holbrook’s response to Calvert and Hartburg’s motion. None of these affidavits make any direct reference to publications by Calvert or Hartburg. To the extent
they can be read to do so indirectly, Calvert and Hartburg incorporate the same arguments and objections raised in
the preceding paragraph.5
B. AN EXERCISE OF JURISDICTION WOULD OFFEND DUE PROCESS; HOLBROOK HAS FAILED TO OFFER ANY EVIDENCE TO SHOW THAT DOBROTT, CALVERT, OR HARTBURG PURPOSEFULLY AVAILED THEMSELVES OF OHIO LAW.
Even if this Court were to conclude that Holbrook has come forward with sufficient evidence to invoke the Ohio long-arm statute—which he plainly has not—Holbrook has no evidence or legal authority to support its claim that Dobrott, Calvert, and Hartburg’s due process rights would not be violated if this Court were to assert personal jurisdiction over them.
Holbrook’s entire argument on this issue is based on selective quotations from the Ohio Supreme Court’s opinion in Kauffman Racing Equip., L.L.C. v. Roberts, 126 Ohio St. 3d 81, 2010-Ohio-2551, 930 N.E.2d 784. The Kauffman Court held that an out-of-state defendant could be subject
to the jurisdiction of Ohio’s courts for defamatory statements posted on the internet about an Ohio corporation. This holding, however, turned on the fact that the plaintiff came forward with evidence of the following to make a prima facie showing that the defendant’s had purposefully
availed himself of Ohio’s laws:
[The defendant] knew that [the plaintiff] was an Ohio company. [The defendant] impugned the activities that [the defendant] undertakes in Ohio. [The defendant] hoped that his commentary would have a devastating effect on [the plaintiff] and that if there were fallout from his comments, the brunt of the harm would be felt in Ohio.
Id. at ¶56. The Kauffman Court held that, to find jurisdiction in Ohio, the tortious activity must have been “calculated to cause injury in a focal point where the brunt of the injury would occur.” Id. at ¶66 (internal quotations omitted). As discussed at length in Dobrott, Calvert, and Hartburg’s motions to dismiss, the facts of this case are clearly distinguishable: (1) Holbrook is not an Ohio-based entity—it’s an Arizonaregistered entity, and Holbrook, the individual, is a Nevada resident; (2) none of Dobrott,
Calvert, and Hartburg’s publications about Holbrook before February 29, 2012 involved its activities in Ohio—they were all about projects in Nevada and Texas; and (3) neither Dobrott,6 Calvert, nor Hartburg had reason to believe that “the brunt” of any alleged harm from their
publications would be felt in Ohio—none of them had any reason to suspect that he was operating in Ohio until February 29, 2012. Accordingly, Holbrook has not made a prima facie showing of purposeful availment, a required element of this Court’s due-process analysis.
As discussed in their motions to dismiss, the facts of this case are properly analogized to Reynolds v. International Amateur Ath. Fedn., 23 F.3d 1110 (6th Cir. 1994), 2 Cadle Co. v. Schlichtmann, 6th Cir. No. 04-3145, 123 Fed. Appx. 675 (Feb. 8, 2005), and Oasis Corp. v. Judd, 132 F.Supp.2d 612, 614 (S.D. Ohio 2001). In all three cases, the courts concluded that Ohio courts did not have personal jurisdiction over non-resident defendants for defamation
claims that arose from out-of-state publications that were not targeted at an Ohio audience or an Ohio entity. The same result should follow here.
CONCLUSION
Holbrook has not made a prima facie showing that either the Ohio long-arm statute or the due process clause of the United States Constitution would permit this Court to exercise personal jurisdiction over Dobrott, Calvert, or Hartburg. Accordingly, Dobrott, Calvert, or Hartburg
respectfully request that all of Holbrook’s claims against them be dismissed pursuant to Civ.R.
12(b)(2).
2
Contrary to Holbrook’s assertion, the Ohio Supreme Court’s opinion in Kauffman did not “reject” the Sixth Circuit’s analysis in Reynolds. Instead, it concluded that “the distinguishing aspects in Reynolds are not in play
here.” Kauffman, at ¶ 60. As discussed in detail in the motions to dismiss, the distinguishing aspects in Reynolds are analogous to the present case.7
Respectfully Submitted,
/s/ Adam R. Webber_________
ADAM R. WEBBER, Esq.
Bar No. 0080900
FALKE & DUNPHY, LLC
30 Wyoming Street
Dayton, Ohio 45409
Phone: 937.222.3000
Fax: 937.222.1414
Email: webber@ohiolawyers.cc
KEVIN W. KITA, Esq.
Bar No. 0088029
SUTTER O’CONNELL
3600 Erieview Tower
1301 East Ninth Street
Cleveland, Ohio 44114
Phone: (216) 928-2200
Fax: (216) 928-4400
Email: kkita@sutter-law.com
MATTHEW J. KITA, Esq.
Admitted Pro Hac Vice
Ohio Bar No. PHV – 2978-2012
Texas Bar No. 24050883
P.O. Box 5119
Dallas, Texas 75208
Phone: (214) 699-1863
Fax: (214) 347-7221
Email: matt@mattkita.com
Attorneys for Third-Party Defendants
Heather Dobrott, Cynthia Calvert, and
Hartburg Publications, LLC8
Anyone needing assistance please feel free to use this e-mail in addition to the PM system here to contact me: soapboxmom@hotmail.com
Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
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LOL, it looks like your attorney has a much better grasp of the law than Suburger.
It seems like in this "industry" common sense is not all that common!
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
It seems like in this "industry" common sense is not all that common!
Hats off to your lawyers, Soapboxmom. Straight and to the point, and also, I might add, written so that a jury of REASONABLE minds would understand what was written, unlike the truckLOAD of blah, blah, blah that was dumped on the Honorable Judge Michael Tucker's doorstep by Sueburger. It makes me wonder if the Supreme Lord and Master of the Internet didn't have a big hand in writing what was dumped there. "Abject speculation built upon heresay" -EPIC!!! Your lawyers just described Holbrook's bloated EarthQuest project also!!! Too bad it couldn't be built on Holbrooks boatload of abject speculations and heresay dumped on the doorsteps of the EMCID, because I'd be typing this right now while waiting to pay my parking fee to the taxpayer's of EMC for the privilege to enjoy EarthQuest.
And of course what could be more amusing than "double hearsay?" The city of Huber Heights already opined that the case had nothing to do with any of the third-party defendants. The case settled around the city's displeasure with Holbrook's work product, plain and simple. I expect that the third-party defendants will find their Motions to Dismiss granted and Holbrook will be standing there fighting the city alone as he should be very soon.
Huber Heights Motion to Strike Third-party Complaint.pdf
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
Oh, come on now, Soapboxmom, out with the truth. We ALL know you hopped on your time-travel broomstick and helped Mr. Gasbag with his work product. LOL
ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Thursday, August 30, 2012 3:37:36 PM
CASE NUMBER: 2012 CV 02947 Docket ID: 17481745
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO2
1
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
CIVIL DIVISION
CITY OF HUBER HEIGHTS, OHIO
6131 Taylorsville Road
Huber Heights, Ohio 45424
Plaintiff,
v.
DON ALLEN HOLBROOK, LLC
9200 Dalmahoy Place
Las Vegas, NV 89145
Defendant.
*
CASE NO. 12 CV 2947
JUDGE MICHAEL TUCKER
CITY OF HUBER HEIGHTS’ ANSWER
TO DEFENDANT’S COUNTERCLAIM
With Jury Demand Endorsed Hereon
____________________________________
Now comes Plaintiff, by and through counsel, and, for its Answer against Defendant’s
Counterclaim, and hereby admits, denies, and avers as follows:
FIRST DEFENSE
1. Plaintiff denies the allegations contained in Paragraphs 43, 50, 52, 54, 55, 56, 58, 60,
62, 65, and 66 of the Counterclaim.
2. With respect to Paragraphs 37, 38, 39, 40, 41, 42, and 63, Plaintiff avers that the
document speaks for itself.
3. Plaintiff admits the allegations contained in Paragraphs 35, 36, 44, 45, 46, 47, 48, 49,
51, and 53 of the Counterclaim.
4. With respect to Paragraph 57, Plaintiff denies for want of knowledge Defendant’s
motivation for sending a litigation hold letter and public records request or if
Defendant had notice of defamatory and derogatory internet postings, but admits the
remaining allegations.
5. Plaintiff denies the allegations contained in Paragraph 59 to the extent a response is
necessary.
6. With respect to Paragraph 61, Plaintiff incorporates completely herein each of the
admissions and denials as set forth above.
7. With respect to Paragraph 64, Plaintiff admits that an actual and justiciable controversy
has arisen, but denies all remaining allegations.
8. Plaintiff denies generally, specially, or for want of knowledge each allegation not
specifically admitted to be true.
SECOND DEFENSE
9. Defendant’s Counterclaim fails to state a claim against Plaintiff upon which relief can
be granted.
THIRD DEFENSE
10. Defendant has failed to join persons and/or claims as required by Civil Rules 19 and/or
19.1.
FOURTH DEFENSE
11. Defendant’s claims against Plaintiff are barred by the doctrines of waiver, estoppel,
and/or laches.
FIFTH DEFENSE
12. Defendant has failed to mitigate its damages, if any.
SIXTH DEFENSE
13. Avers the absence and/or failure of consideration.
SEVENTH DEFENSE
14. Avers there was no meeting of the minds.
EIGHTH DEFENSE
15. Avers that Defendant failed to fulfill its implied contractual duty of good faith and fair
dealing with Plaintiff.
NINTH DEFENSE
16. Defendant’s Counterclaim is barred and/or proportionately reduced as a result of its
acts or omissions.3
TENTH DEFENSE
17. Defendant’s claims are barred by the doctrines of parol evidence and/or merger.
ELEVENTH DEFENSE
18. Defendant’s injuries and damages, if any, are the result of acts and/or omissions of
others over whom this answering Plaintiff had no right or opportunity of control.
TWELFTH DEFENSE
19. Defendant’s claims are barred by the equitable doctrine of payment.
THIRTEENTH DEFENSE
20. Plaintiff avers there was a mutual or unilateral mistake.
FOURTEENTH DEFENSE
21. Plaintiff avers there was a failure of performance on the part of Defendant.
FIFTEENTH DEFENSE
22. Defendant’s claims are barred because Defendant failed to satisfy a condition
precedent.
SIXTEENTH DEFENSE
23. Defendant’s claims are barred by the doctrine of unclean hands.
SEVENTEENTH DEFENSE
24. Defendant anticipatorily breached the contract.
EIGHTEENTH DEFENSE
25. Defendant’s claims are barred by the doctrine of fraudulent inducement.
NINETEENTH DEFENSE
26. Defendant’s claims are barred by the doctrine of misrepresentation.
TWENTIETH DEFENSE
27. Defendant’s Counterclaim fails to comply with the requirements of Ohio Civ. Rule 57
and O.R.C. §§2721.01 to 2721.15. 4
TWENTY-FIRST DEFENSE
28. Because Defendant’s Counterclaim states damages, injunctive relief is inappropriate.
TWENTY-SECOND DEFENSE
29. Defendant has failed to take appropriate action to create, maintain or enjoy any
proprietary interest in alleged trade secrets or to take efforts to keep such materials
confidential.
TWENTY-THIRD DEFENSE
30. Plaintiff reserves the right to further plead additional affirmative defenses as same
become known during the course of this litigation.
WHEREFORE having fully answered the allegations contained in Defendant’s
Counterclaim Plaintiff prays the same be dismissed at Defendant’s cost.
Respectfully submitted,
/s/ L. Michael Bly
L. Michael Bly (0042074)
Joshua M. Kin (0086965)
PICKREL, SCHAEFFER & EBELING CO.
2700 Kettering Tower
Dayton, Ohio 45423
Telephone: (937) 223-1130
Facsimile: (937) 223-0339
mbly@pselaw.com
jkin@pselaw.com
Attorneys for Plaintiff
JURY DEMAND
Plaintiff demands a trial by a jury on all issues of the within cause.
/s/ L. Michael Bly
L. Michael Bly (0042074)
PICKREL, SCHAEFFER & EBELING CO.5
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was served by the Court’s e-filing system on this
30
th
day of August 2012, upon the following:
Sue Seeberger
Attorney for Defendant/Third-Party Plaintiff Don Allen Holbrook LLC
Robert P. Bartlett
Andrew J. Reitz
Attorneys for Third-Party Defendants Stephens Media LLC d/b/a Pahrump Valley Times; and
The Houston Press, The Houston Press d/b/a Village Voice Media Holdings LLC d/b/a
Houston Press LP d/b/a Backpage.com LLC; and Craig Malisow
Adam R. Webber
Kevin W. Kita
Attorneys for Third-Party Defendants Heather Dobrott, Cynthia Calvert, and Hartburg
Publications LLC
Frank Maurizio
Attorney for Third-Party Defendant Frank Maurizio
/s/ L. Michael Bly
L. Michael Bly (0042074)
Holbrook Counterclaim Huber Heights.pdf
That was the city's answer to Holbrook's ridiculous counterclaim. Notice the city denies among many other things:
52. Upon information and belief, on or before March 14, 2012, defamatory, untrue, derogatory, and false postings from internet bloggers about Don Allen Holbrook, LLC were distributed and circulated to the City Staff and members of the City Council without any notice to Don Allen Holbrook, LLC.
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
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City of Huber Heights says:
SIXTEENTH DEFENSE
23. Defendant’s claims are barred by the doctrine of unclean hands.One of the maxims of equity embodying the principle that a party seeking redress in a court of equity (equitable relief) must not have done any dishonest or unethical act in the transaction upon which he or she maintains the action in equity, since a court of conscience will not grant relief to one guilty of unconscionable conduct, i.e., to one with “unclean hands.”EIGHTEENTH DEFENSE
25. Defendant’s claims are barred by the doctrine of fraudulent inducement.fraud in the inducement n. the use of deceit or trick to cause someone to act to his/her disadvantage, such as signing an agreement or deeding away real property. The heart of this type of fraud is misleading the other party as to the facts upon which he/she will base his/her decision to act. Example: "there will be tax advantages to you if you let me take title to your property," or "you don't have to read the rest of the contract--it is just routine legal language" but actually includes a balloon payment. (See: fraud, extrinsic fraud)
Copyright © 1981-2005 by Gerald N. Hill and Kathleen T. Hill. All Right reserved.
NINETEENTH DEFENSE
26. Defendant’s claims are barred by the doctrine of misrepresentation.No doubt Don Allen Holbrook handed them the bull he has published in writing all over the internet and had in this video he has since been forced to remove:fraudulent misrepresentation
Definition
Instance of false statement where (1) the party making the statement is aware that it is false or disregards the possibility of it being false, (2) the party making the statement does so to induce another party to enter into a contract, and (3) the other party enters the contract as a result of the statement and consequently suffers a loss.
http://www.realscam.com/f11/don-alle...240/#post19582
He claims that he has put together 100s of economic development deals worth over billions of dollars that have created over 50,000 jobs in this country??? I wonder what else the city will complain of related to all this???
Soapboxmom
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
Memo to Sir Holbrook (PigPen) concerning the City of Huber Heights SIXTEENTH DEFENSE ; Buzz and Woody have generously decided to donate a 55 gallon drum of industrial strength Mr. Clean to wash thy filthy hands!
These posts have long since disappeared from the dino park forum, but are archived elsewhere. Perhaps, Holbrook would like to tell us again about the updated business model, names of the theme park industry experts on this board of advisers (which I am positive is a figment of his imagination,) and the amount of capital raised to fund this clunker. Who are the investors that are stupid enough to "pay off the public investment in the project" i.e. his wild spending sprees? Is Holbrook prepared to substantiate all this in discovery?Reposted from houstondinopark.com
Very interesting comments by Don Holbrook - Economic Development Representative of EarthQuest
Comment by: Don Holbrook on Mar. 9th, 2012
With regard to all the rumors and unjust comments about EMCID and Frank McCrady, I can truly say this about the entire situation:
Just because John Marlin as the original developer failed to perform does not mean he did so with malicious intent. I believe we experienced and most Americans still are experiencing one of the worst global financial crisis in most of our lifetimes. He simply was trying to do this and did not know the economy would tank and thus his investors ran for cover as did thousands of other projects across the globe... Almost every city, town and region has faced this same scenario. Many with no hope of turning their plight around.
But not EMCID, led by Mr. McCrady. EMCID looked at it strategically and said if we are to improve our local economy we have to focus on being a destination in our region. They diversified and began working on more than just EarthQuest to build visitor draw and ancillary and complimentary tourism projects that employ people, fill hotel rooms, buy gas, food and other things. These efforts diversified their risk and made them not so dependent on just the success of EarthQuest. Those actions are now bearing fruit... Wake Boarding is hugely popular and will attract residents from all over Houston to EMCID territory to spend money and guess what employ people. Then they attract the worlds #1 Firearms Training Institute to build their new $25M plus state of the art world headquarters to EMCID besting out San Antonio for the project, which attracts over 25,000 trainees from around the world on NV and they expect to do over 60,000 in Texas. Those create nearly 300,000 room nights, consume food & beverages and buy gas and other retail items while in EMCID territory.
Not a bad outcome considering the great economic transition we are in. But I'm not skipping EarthQuest. EMCID once Marlin made them award he couldn't perform began making plans for how to mitigate Marlins lack of performance. They did not sulk or stick their head in the sand. They asked Chris Brown, one of the worlds foremost theme park designers to consider becoming the developer. He accepted the challenge and began planning the mitigation. He began by updating the business model so it would be valid in the post 2008 economic meltdown. Then he started building an astute board of advisors from the theme park industry and raising capital so that he could do the most important first step, regain site control once the Bankruptcy Court and the Bank were willing to allow such actions. This was controlled not by EMCID or Chris Brown but our judicial system.
Meanwhile EMCID strategically made all the right moves to protect the project so it could move forward. They positioned their interest in the land at no additional cost so they could provide Brown the new developer with an option to purchase the land from the BK proceedings. They clawed back all intellectual rights to the project and wrote a new and much stronger new development agreement requiring the new developer to license the Intellectual Property for a fee that would be enough to pay off the public investment in the project.
Most important they remembered that Marlins failure did not mean the project was not viable. Three different world renowned theme park experts all agreed Houston is the best market in the central time zone for a major Theme Park. So EMCID made sure the project would continue to move towards successful opening even if the developer failed. In my opinion EMCID and McCrady did their job excellent and because of their actions, someday soon Greater Houston will have one of the greatest theme park attractions in America. EMCID's strategic vision and perseverance will prove to have been strategically well executed and produce exceptional economic outcomes for their constituents. I feel so sad that these good people have endure such horrible abuse from some in the general public while doing their peers such a great outcome. Now that the Marlin scenario is beginning to settle out EMCID is moving forward just as it appears the economy is beginning to invest again. I know they will do excellent. I also believe Chris Brown deserves our full support as he works hard to get a great project back on track.
Comment by: Don Holbrook on Mar. 9th, 2012
Slander and defammation are easy to do and show the lack of intelligence of those that smear others with no regard for facts. Factual analysis that is not jaded requires intellect. I have found these comments to be wildly unfactual.
Here are some facts. Since you all enjoy googling so much. Find one failed project, one customer complaint, or any factual misconduct that is not just bloggers or hyperbole. You can't. They don't exist because I have done excellent projects, well over 100 and those projects have employed over 50,000 hard working Americans. These outcomes led my International Association of peers the international economic development council, made up of over 5,000 professionals to award me their highest honor of Fellow Member in 2008, for excellence in the profession and lifetime achievement. Less than 1% of my peers will ever win this award. Furthermore, projects of great magnitude take time to unfold and often face set backs, but they work through them and eventually succeed. Then everyone cheers how wonderful, and they claim they always supported it. Truth is great projects take vision, perseverance and thick skin to tolerate all those that lack such qualities. Almost forgot most people also overlook that I am the #1 author in my industry worldwide, #1 keynote public speaker world wide in economic development and one of the most sought out public policy consultants on economic development in the world. Communities seek me out I don't sell myself through marketing and advertisements but through word of mouth testimonials and references from satisfied clients... That is how I make a living, advising my clients on the best course of action to achieve the problem or opportunity they have asked me for advice on.
EMCID clawed back the intellectual property rights from whom? We have been told it was Don Lessem's baby and he wanted the rights back by 2014. We have been told EMCID has the rights and then we have also been told Contour had the rights and wouldn't cooperate with Don Lessem's demands. Who really does have them? Where is the documentation on this? More fodder for discovery no doubt!
If Holbrook is one of the most sought after public policy consultants on economic development in the world, then why does his bankruptcy show EMCID as his only source of income? And, why is his income always below $100,000.00 a year if he is beating off the clients and has had so many successful projects? There is some really funny math going on here!
Holbrook certainly knows how to best advise his "clients on the best course of action to achieve the problem." We certainly do have a problem and Holbrook is making quite a handsome living off of the taxpayers of Texas! Holbrook / his LLCs were paid at least 1.2 million dollars from 2007-2010. 2.5 million was blown by EMCID from the regular budget and the taxpayers are on the hook for 21 million in bonds that must be satisfied. This is a disaster of Jurassic proportion. It is time for some serious digging!
Soapboxmom
Anyone needing assistance please feel free to use this e-mail in addition to the PM system here to contact me: soapboxmom@hotmail.com
Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
Well, I don't know about Gasbag beating off his clients, Soapboxmom, but he sure stroked the crap out of EMCID's checkbook! That was a Texas size wad (of cash) Frank (the Bank) shot into Gasbag's bank account. I'm wondering what the Texas Attorney Generals Office has dug up so far. Hmmmmmm........
Holbrook has been paying around $35,000.00 a year to have his two sons in a very exclusive private school. Online posts show definitely that his oldest son was at this school where only 18% are given financial aid. He was wallowing in chapter 7 bankruptcy from 2007-2010. He filed for chapter 11 bankruptcy in the fall of 2011 and is still tangled up in that mess. How is he funding this? He wrote off 1.89 million in 2010 including 1.29 in attorney fees alone. Now, he is trying to weasel out of mountains of debt and restructure loans, yet he can afford this pricey prep school???
Ian Holbrook's Meadows High School 09-10 Baseball Profile
Ian Holbrook's Meadows High School 10-11 Baseball ProfileIan Holbrook
Jersey:9Pos:INF, PClass: Fresh
School: Meadows Mustangs Season: Varsity 09-10 Sport: Baseball Overall: 15-12-0 League: 10-4-0 National Rank:11695NV State Rank:5
Ian Holbrook's Meadows High School 11-12 Basketball ProfileIan Holbrook
Jersey:9Pos:INF, PClass: Soph. School: Meadows Mustangs Season: Varsity 10-11 Sport: Baseball Overall: 22-7-0 League: 12-2-0 National Rank:8538NV State Rank:47
Ian Holbrook's Meadows High School 2011 Football Profile - MaxPreps.comIan Holbrook
Jersey:21Pos:PFHt/Wt:6'1"/185Class: Jr. School: Meadows Mustangs Season: Varsity 11-12 Sport: Basketball Overall: 22-7-0 League: 12-2-0 National Rank:7111NV State Rank:40
Ian Holbrook
Jersey:66Pos:OL, DLClass: Jr. School: Meadows Mustangs Season: Varsity 11-12 Sport: Football Overall: 8-3-0 League: 6-1-0 National Rank:9503NV State Rank:48
Ian Holbrook's Meadows High School 2009 Football Profile - MaxPreps.comBaseball Recruiting / Nevada / Las Vegas, NV / The Meadows School / Ian Holbrook Ian Holbrook ‘13 Recruiting Profile
- The Meadows School
- Las Vegas, NV
- Baseball
Club:VenomHeight:6'2"Weight:190Dominant Hand:RightAge:17Prim. Position:RHPSec. Position:3B Bench Press180Squat350Top Fastball82FB76Change Up67Breaking Ball68Top Infield Velocity82Infield Velocity78Top Outfield Velocity82Outfield Velocity78
Ian Holbrook
Jersey:76Pos:N/AClass: Fresh
School: Meadows Mustangs Season: Varsity 09-10 Sport: Football Overall: 11-1-0 League: 7-0-0 National Rank:5273NV State Rank:25
Again, how is a guy claiming $90,000.00 in income in 2009 paying for this school and touring Europe while wallowing in chapter 7 bankruptcy. The IRS and DOJ need to be looking at this carefully.
NEWS | SCHEDULE/SCORES | ROSTER | LEADERS | HISTORY |
HOME > BASKETBALL > TEAMS > THE MEADOWS BOYS BASKETBALL 2011-2012 > ROSTER
No. Name Pos. Ht. Wt. Cl. 4 Matt Biafore G 5-9 115 So. 5 Max Newman G 5-10 155 Sr. 12 Richard Lee G 5-10 155 Sr. 21 Ian Holbrook F 6-1 185 Jr. 22 Garrett Gosse F 6-3 170 Sr. 23 Brian Fridman G 5-10 115 So. 32 Michael Gleason C 6-1 190 Jr. 34 Torrey Mayes F 5-10 170 Sr. 42 Brandon Rufty F 6-2 155 So. 44 Eric Hirsberg G 5-11 155 So. 50 Adam Aziz C 6-4 170 Jr.
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
http://www.realscam.com/f11/don-alle...html#post21317
This bragging has gone on since 2006. There is no patent in the name of Don Holbrook or Don Allen Holbrook. Where is this patent years later??? I searched patents for the International Economic Development Council and subject areas as well.He is regarded by many as one of the leading subject matter experts in the field on technology based site selection and creative financing for public investments in catalyst private sector projects. He is the developer of the patent pending dynamic site location database model now currently licensed to the industry with the IEDC.
The only thing close I could find was this and Holbrook had nothing to do with it:
United States Patent: 7266566
Holbrook's penchant for fictionalizing was well documented by our good man Craig Malisow. Of course, Holbrook dismissed the frivolous, harassment suit against him and his fine paper for obvious reasons. Malisow was right on the money about everything and Holbrook must realize he can't touch him.
EarthQuest's Don Holbrook Threatens to Sue Critics into Submission - Houston - News - Hair Balls
Holbrook's self-composed blurb on Wikipedia takes the cake:
So fabulous to have all this in black and white viral all over the internet! His talk of his peers coveting his style is certainly not what I am getting from the people I am talking to. Since all his work from 2006 on seems to be promoting the failed Earthquest project, the controversial Pahrump proposal from which he was unceremoniously booted and his latest debacle in Ohio, where are these successful projects showcasing the talents he brags of???User:9thTemplar
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Don Holbrook, Certified Economic Developer
Don Holbrook has been engaged in economic development since 1991. His passion is to create an environment in local communities that fosters sustainable economic growth and access to economic opportunities for citizens. His primary focus has been to create catlyst models to engage local strengths and eliminate and/or diminish local problems or barriers to such growth. Holbrook has been a maverick and over the horizon public policy thinker. His reality based reviews of communities can sometimes draw criticism from locals because they do not understand that change and progress are not always comfortable. Holbrook has been called by his peers a change agent. He is progressive and not afraid to identify the root issues that inhibit communities from reaching their potential. Holbrook feels that if our world, our nation and communities are going to reach their true potential we have to embrace new ideas and concepts that are constantly evolving. This constant inertia creates rapid changes in the fortunes of communities. His over the horizon ability to see changes in the economics of communities has been keen. What Holbrook has found however is that many communities profess they desire progress and change but unequivocably fight the transition when confronted with decisions to meet those challenges. His style has been controversial to some and coveted by his peers and others for his effectiveness at hitting the mark. Holbrook created a process he calls the Seven Step Process for Community Economic Don Holbrook 00:41, 23 October 2006 (UTC)Development. This takes a community from start to finish in designing a reality based blueprint to increase their local economic growth and create a sustainable economy. His approach identifies areas that need change and focuses on how to pay for and implement those changes within the resources available to communities. Holbrook says communities must take calculated risks to create new economic horizons, but they must really calculate the risk and then measure that against the possibility of return of investment. His pioneering methods have created new incentive models, community profiling resources and internet enabled strategies as contributions to the economic development industry.
Holbrook has a patent pending Dynamic Distributed Internet enabled database model for site location and community profile ranking at the U.S. Patent office and has licensed this model for use by the International Economic Development Council, IEDC. His hopes are that economic developers learn how to embrace technology as a cutting edge tool to add to their capabilities. He has been instrumentally involved in the establishment of the IEDC site location data standards. Holbrook launched the first economic development web site in the world in 1991 and has been an economic development pioneer and social scientist ever since then. He loves to work with communities to find their best qualities and build upon their strengths to compete for new business and economic growth. While he has been chastized by some community leaders for his change oriented methods, he has remained a positive force in this drive to better community economic development. His positive attitude allows for the public frenzy as what he called "Justifiable fear of change." People fear change because they do not feel comfortable with the unknown. What I fear is outside forces changing their lives in a very negative manner because they did not seek to answer "What If?" and "How could we improve our local economies?"
Holbrook has lectured to thousands of economic developers. He has written numerous articles in trade journals and the economic development journals. He has been interviewed on Fox Television, by the Wall Street Journal, Washington Post, New York Times, USA Today and other local newspapers. He has written regular articles for Business Facilities and Expansion Management magazines. He currently is working on two books related to economic development and is seeking his doctorate in community economic development.
Soapboxmom
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Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
Don Allen Holbrook and his wife Laurie did not seem to list the private school tuition for their sons as an expense on their latest bankruptcy. How does on avoid listing a $35,000.00 a year expense on a chapter 11 bankruptcy? If they can afford the tuition for The Meadows, why are they not paying the $148,200.00 in taxes they owe plus the thousands more owed to creditors? Holbrook's bankruptcy seems to be one that is abusing that protection that can be vital for families that are truly in crisis. How is this clown getting away with this??? Where is the money for the exclusive prep school coming from?
Don Laurie Holbrook Bankruptcy Filing .pdf
Anyone needing assistance please feel free to use this e-mail in addition to the PM system here to contact me: soapboxmom@hotmail.com
Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
Where are these sucessful projects showcasing the talents he brags of ??? Why, that's an easy one, they're located in the blob of flesh supported by his neck, right in between his ears
http://www.bap1.uscourts.gov/bap.pdf...ns/03-078P.pdf
Shouldn't Holbrook's many creditors that are just getting screwed know what he is spending on private school in lieu of paying them? He is asking to restructure loans and planning on paying the unsecured creditors (credit cards and more) only 21% of what he owes. This is totally dishonest when he apparently has $35,000.00 to pay for private school for his kids! An outrage!
Holbrook Second Modified Plan of Reorganization.pdf
Anyone needing assistance please feel free to use this e-mail in addition to the PM system here to contact me: soapboxmom@hotmail.com
Dallas College Richland Campus Music Advising Derrick Logozzo / Melissa Logan / Not NASM Accredited / Out of State Tuition Nightmare!
Love some Bunny! I do!
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