JOHN PAUL DEJORIA’S DISREGARD FOR HUMANITY AND LAW CONTINUES…..(ROKSTARS AND ROKIT)

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JOHN PAUL DEJORIA’S DISREGARD FOR HUMANITY AND LAW CONTINUES…..(ROKSTARS AND ROKIT)

Hmmmmm…Let’s see…..THREE DEAD PARTNERS, ONE PUT IN JAIL, TERRORIZATION OF A WOMAN, ME, STOCK FRAUD, (for years, past blog) CORRUPTION IN TEXAS COURTS, LATITUDE SOLUTIONS…….

THE LIST GOES ON AND ON……..

John Paul DeJoria’s GREED AND RAMPAGE of the earth….CONTINUES…..

~ Is there anything worse than a billionaire who doesn’t pay his bills?

What he owes his victims is just pennies to him. ~

HE HAS RACKED UP MORE VICTIMS….AND AS USUAL HE SURROUNDS HIMSELF WITH THE LOWEST SCUM ON EARTH….

THEN SAYS “IT WASN’T ME.”

HE RUNS, AND HIDES, LIKE A P***Y…THEN HE AND HIS GANG, SPLIT THE MONEY BAG, LATER…..$$$$$$$$$$

ALL THE WHILE STEALING, ROBBING, RAVISHING THIS EARTH……ONE PURE UGLY, GREEDY, F**CKER………

NO END EXISTS TO THE DEJORIA FAMILY GREED!!! PROVEN!

~ JP is a bad guy pretending to be a good man. It’s amazing how, just by donating some money to charities,
(solely for tax write offs), it disguises his bad character – so he appears to be a great guy. ~

OHHHH……THE SATANIC PLAYBOOK……LEARNED FROM HIS SODOMY BRO’S, GEORGE BUSH, BILL GATES, AND WARREN BUFFET!

Well…..SADLY! THANK GOODNESS, FOR PUBLIC RECORDS! JOHN PAUL DEJORIA CAN NOT QUIT….AT THE CRUSTY, AGE OF 77…..

LOOKING LIKE, HE IS IN HELL,…..HE CAN NOT STOP….. A BILLION IS NOT ENOUGH!

ANOTHER VICTIM……I AM SO SORRY……

JOHN PAUL DEJORIA IS RUNNING ROKSTARS AND ROKIT?

AND, HIDING OUT BEHIND, JONATHAN KENDRICK, HIS BRITISH, CRIMINAL, PAID, FALL GUY……

JONATHAN KENDRICK, WOULD LICK JOHN PAUL DEJORIA’S, SODOMIZED, ASSHOLE, TO STAY IN HIS $20,000 a month RENTED, PACIFIC PALISADES HOME!

Jonathan Kendrick is NOT EVEN, AMERICAN….HE NEEDS SHIPPED OUT!

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, STANLEY MOSK COURTHOUSE

NOTICE OF MOTION AND MOTION TO
COMPEL DEPOSITION OF JOHN PAUL
DEJORIA AND IMPOSE MONETARY
SANCTIONS AGAINST ROK STARS PLC,
ROK DRINKS LTD.; MEMORANDUM OF
POINTS AND AUTHORITIES;

MEMORANDUM OF POINTS AND AUTHORITIES

I. INTRODUCTION

This is a breach of contract and fraud action wherein, Plaintiff Jeff Moses (“Plaintiff”)

alleges that Defendants ROK Drinks, Ltd. (“ROK Drinks”), ROK Stars PLC (“ROK Stars”), and

Jonathan Kendrick (together, “Defendants”) failed to uphold their promise to pay Plaintiff $250,000

of stock in ROK Stars to acquire an interest in his Graffiti Wine brand.

Through this motion, Plaintiff seeks to compel John Paul DeJoria (“DeJoria”) to appear at

oral deposition. Alongside Defendant Kendrick, DeJoria is a co-founder of Defendant ROK Stars

and ROK Drinks. He is responsible for making management decisions in ROK Stars and directing

its board. DeJoria’s approval was required before ROK Drinks could enter into contracts, such as

the Memorandum of Understanding between Plaintiff and Defendants (“MOU”). DeJoria was also

intimately involved in all aspects of ROK Stars and ROK Drinks’ business, including the Graffiti

Wine brand at the center of the instant dispute.

Neither Defendants nor DeJoria filed a timely objection to Plaintiff’s deposition notice, but

Defendants nevertheless refused to produce DeJoria for his properly noticed deposition arguing that

he is not a “party affiliated witness.” This is simply untrue as there is a wealth of evidence that

DeJoria is a managing agent of both ROK Stars and ROK Drinks. They are thus obligated to

produce him for deposition pursuant to the Rules of Civil Procedure. C.C.P. § Section 2025.280(a).

Plaintiff also seeks reimbursement for reasonable expenses and costs incurred as well as attorney

time spent as a result of Defendants’ failure to produce DeJoria.

II. RELEVANT BACKGROUND

Plaintiff first noticed the deposition of DeJoria on August 5, 2021, with the deposition set to

take place on September 22, 2021. Declaration of Max Ambrose (“Ambrose Decl.”), ¶ 2, Ex. A.

A. DeJoria’s Managerial Role

DeJoria’s role as a managing agent of ROK Stars and its subsidiary ROK Drinks is clear.

Ambrose Decl. ¶¶ 10-19; Declaration of Jeff Moses (“Moses Decl.”) ¶¶ 2-9. As shown below, the

front page of the ROK Stars website proclaims “ROK Stars was founded by US Billionaire John

Paul DeJoria and UK serial entrepreneur Jonathan Kendrick.” Id. ¶ 10, Ex. G. ROK Drinks, which

has since rebranded as ROKiT Drinks, similarly identifies DeJoria as “Co Founder” on its public

website which dedicates a full page to detailing DeJoria and Kendrick’s background. Id. ¶ 11, Ex.

H.

DeJoria attended meetings with the president of ROK Drinks, Alison Kennedy. Id. ¶ 19, Ex.

O, Deposition Transcript of Alison Kennedy at 27:22-24 (“Tr.”). And Defendant Kendrick took

instructions directly from Mr. DeJoria. Id., Ex. O, Tr. 27:25-28:2. DeJoria was likely funding ROK

Stars and/or ROK Drinks on a monthly basis because of cash flow problems. Id., Ex. P, Tr. 97:10-

17; 98:10-14. Moses Decl. ¶ ¶ 5-7.

Defendants’ internal records and communications confirm that DeJoria takes a significant

role in managing company operations and directing the board of ROK Stars. For example, in

November 2017, Mr. Kendrick sent an email from his ROK Stars email address to a colleague

regarding ABK beer, stating “I spoke with jp [DeJoria] yesterday day. He does not want to

purchase the storage facility at this time for 1.8 and said to me specifically, lets use the cash we

have in the Ag to promote and market ABK.” He continues, “[o]n the land I will see jp [DeJoria]

this Friday to get all clear for the supervisory board to sign.” Ambrose Decl.. ¶ 12, Ex. I. In August

2015, Kendrick sent another email regarding ABK beer to his ROK Stars colleagues stating “[l]ooks

like jp [DeJoria] has pulled some strings” in his aid of import and sale of ABK Beer in Texas. ¶ 13,

Ex. J.

DeJoria’s JP’s Nevada Trust also acquired the remaining stake of ABK Beer not already

owned by ROK Stars, which is relevant to the instant action. Id. ¶ 15, Ex. L. ROK Drinks, a

division of ROK Stars marketed both ABK Beer and Graffiti Wine. Id., Ex. L.

Critically, DeJoria’s permission was also necessary for certain ROK Stars’ contract

acceptances and was necessary for the MOU at the center of this dispute. Moses Decl. ¶ 2-3; see

also Ambrose Decl. ¶ 16, Ex. M (October 2017 email from Kendrick to ROK Stars colleagues

regarding a distillery purchase Memorandum of Understanding and stating ““[u]nfortuantely John

paul [DeJoria] is on holiday and cannot commit.”

When Plaintiff first met with Defendant Kendrick in 2015 to discuss ROK Drinks acquiring

the Graffiti Wine Brand, Kendrick told Plaintiff he loved the brand, but would have to get DeJoria’s

approval before any agreement could be reached. Moses Decl. ¶ 2. During Plaintiff’s next meeting

with Kendrick, Kendrick informed Plaintiff that DeJoria had given his approval for the acquisition,

loved the Graffiti Wine Brand, and wanted to purchase it. Id. ¶ 3.

Around the time of ROK Drinks’ acquisition of the Graffiti Wine Brand, Plaintiff met faceto-

face with DeJoria to discuss DeJoria’s direction on the Graffiti Wine Brand. Id. ¶ 4. DeJoria

directed Plaintiff to pursue specific countries in which to produce and distribute Graffiti Wine,

including Spain, Italy, and Mexico. Id. In that meeting, DeJoria also told Plaintiff directly that he

loved the brand and was happy to have purchased it. Id.

When Kendrick and Plaintiff were in discussions regarding producing and marketing

Graffiti Wine in Italy and India, Plaintiff met with DeJoria again to discuss distributions plans of

Graffiti Wine in these countries. Id. ¶ 5. DeJoria’s final approval was required before ROK Drinks

could make any decision on where to distribute Graffiti Wine. Id.

In 2015, Plaintiff negotiated a $250,000 deal for ROK Drinks to purchase the Amador

Distilling Company. Id. ¶ 6. Once the negotiations were nearly finalized, Plaintiff met with

Kendrick in his office and explained the deal. Id. Kendrick informed Plaintiff that he had to get the

money from DeJoria before entering any agreement. Id. In that same meeting, Kendrick called

DeJoria on speaker phone explaining the $250,000 deal and requesting the money from DeJoria.

DeJoria ultimately agreed. Id. Dan Lewis, ROK Drinks’ accountant later told Plaintiff the check

and money for the ROK Distillery came directly from DeJoria. Id.

During Plaintiff’s weekly meetings over the course of his time at ROK Drinks, Kendrick

mentioned about a dozen times that he must check with DeJoria first before making financial or

management decisions for ROK Drinks. Id. ¶ 7. Kendrick often called DeJoria directly in these

meetings, placing him on speaker phone, to ask for his permission on financial and management

decisions. Id.

Around October 2017 when Plaintiff requested ROK Drinks distributors carry the Graffiti

Wine Brand, Kendrick informed Plaintiff that ROK Drinks would not be doing that because DeJoria

preferred to phase out the brand. Id. ¶ 9. After Plaintiff’s termination by ROK Drinks, Plaintiff

called DeJoria and spoke with him on the phone. Id. During that phone call, DeJoria admitted to

Plaintiff that both him and Kendrick bought the Graffiti Wine brand but when Plaintiff asked him

why he did not compensate Plaintiff as promised, he explained that Plaintiff made the deal with

Kendrick, and would have to deal with him. Id.

In sum, DeJoria’s management role at both ROK Stars and ROK Drinks is clear and his

extensive involvement in the matters at the core of this case is illustrated by Defendants’ own

documents, the testimony of ROK Drink’s former president, Alison Kennedy, and Plaintiff’s

declaration.

B. Procedural Background

Upon service of the Deposition notice, Plaintiff’s Counsel expressed his willingness to

“work with your schedule” on the noticed dates and indicated he had “no problem rescheduling to

another reasonable date,” but stated that “[i]f we do not hear back from you by Friday, August 20,

2021, we will assume that these dates work for you and we will proceed accordingly.” Ambrose

Decl. ¶ 3. Merino responded to Plaintiff’s Counsel’s service on August 18, 2021, without raising

any issues regarding the timing of DeJoria’s deposition. Id. ¶ 4. Merino merely asked Plaintiff’s

Counsel to “identify the scope of the DeJoria Deposition” and made no indication at that time he

planned to object. Id.

Plaintiff’s Counsel responded to Merino on August 25, 2021 by identifying the matters on

which Plaintiff planned to question DeJoria and confirming that based on Mr. Merino’s “earlier

emails, it is our understanding that both Mr. Kendrick and Mr. DeJoria are available on September

14 and September 22 respectively.” Id ¶ ¶ 4-5. Once again Merino did not object to the September

22, 2021 date or provide any indication that the DeJoria deposition was otherwise objectionable. Id.

¶ 5. From August 5 to September 13, neither Merino nor DeJoria provided any indication that

Defendants would not produce DeJoria for his September 22 deposition. Id. at ¶ ¶ 4-6.

On September 13, 2021, Merino indicated for the first time there were “substantial issues

with whether the deposition of Mr. DeJoria was necessary or appropriate” and would send a letter

later that week. Id. ¶ 6. On September 15, 2021 Merino sent a Meet and Confer letter (the “Letter”)

which asserted that (i) DeJoria does not qualify as an employee, officer, director, or managing agent

of any party to this action (ii) claimed that DeJoria has no role in this dispute, then requested that

we forego DeJoria’s deposition, and (iii) claimed that Plaintiff’s noticed deposition of DeJoria

violates the local rules that require depositions be taken in order of notice. Id. ¶ 7, Ex. C.

Plaintiff’s counsel responded to this letter on September 20 by sending a detailed email to

Merino identifying and attaching records illustrating DeJoria’s managerial role at Defendants and

his key role in the matters at the heart of this litigation. Id. ¶ 8-10. This meet and confer email

made it clear that Plaintiff intended to proceed with the deposition of DeJoria as scheduled. Id.

Merino did not respond to this email. Id.

Following Merino’s failure to respond to the September 16 email, Plaintiff’s counsel once

again reached out to Merino on September 20, 2021 asking if Merino was available to discuss the

issues surrounding his deposition. Id. ¶ 21. On September 22, 2022, the date of DeJoria’s

deposition, Plaintiff’s counsel met and conferred via phone call regarding DeJoria’s deposition.

Merino continued to refuse to make DeJoria available for deposition. On that same day, Defendants

failed to produce DeJoria for his properly noticed deposition, despite not having served any valid

objection. ¶ ¶ 22-23.

On September 23, 2021, one day after DeJoria’s properly noticed deposition, Defendants’

counsel mailed an Objection to Notice of Deposition of DeJoria (the “Objection”) to Plaintiff.

Although the Objection’s Proof of Service states that it was mailed on September 21, 2021, the

Shipment Tracking Information shows that the Objection was mailed on September 23, 2021 at 8:57

PM. Id. ¶ 23, Ex. T, Ex. U.

In a final effort to avoid filing a Motion to Compel, Plaintiff filed a Request for Informal

Discovery Conference. The Court informed Plaintiff that it could conduct the Conference on

October 4, 2021. Id. ¶ 25-26, Ex. W, Ex. X. However, Merino indicated he could not attend the

Conference on that date, even though the conference could be conducted telephonically. Id.

In sum, Plaintiff properly noticed the deposition of DeJoria. Defendants went nearly a

month and a half without raising any issues regarding the deposition itself or its timing. Defendants

failed to produce DeJoria for his properly noticed deposition despite not having served any

Objection to that deposition, and Defendants’ counsel mailed its Objection to DeJoria’s properly

noticed deposition a day after DeJoria’s deposition was scheduled.1

Now, Defendants have continued to refuse to produce DeJoria for deposition. This

unjustified refusal has forced Plaintiff to incur significant legal costs. Moreover, without obtaining

critical testimony from DeJoria, Plaintiff’s ability to litigate this action will be severely prejudiced.

III. THIS COURT SHOULD COMPEL DEJORIA’S ATTENDANCE AT DEPOSITION

AND THE PRODUCTION OF THE DOCUMENTS DESCRIBED IN THE NOTICE

It is Plaintiff’s right to take the deposition of DeJoria. CCP § 2025.010. DeJoria is a

managing agent of both ROK Stars and ROK Drinks. See Ambrose Decl; Moses Decl. Moreover

neither Defendants nor DeJoria served a valid or timely objection to Plaintiff’s deposition notice.

Ambrose Decl. ¶ ¶ 22-23, Ex. Q, Ex. R. A deposition subpoena is not required to compel the

attendance of an officer, director, or managing agent or employee of a party. C.C.P. § 2025.280(a).

A. Neither Defendants nor DeJoria served a valid or timely objection to his

properly noticed deposition and thus waived any right to object.

“If, after service of a deposition notice, a party to the action or an officer, director, [or]

managing agent . . . without having served a valid objection under Section 2025.410, fails to appear

for examination, or to proceed with it, or to produce for inspection any document or tangible thing

described in the deposition notice, the party giving the notice may move for an order compelling the

deponent’s attendance and testimony, and the production for inspection of any document or tangible

thing described in the deposition notice . . .” C.C.P. § 2025.450. A party objecting to deposition

notices under the California Code of Civil Procedure “waives any error or irregularity unless that

party promptly serves a written objection specifying that error or irregularity at least three

calendar days prior to the date for which the deposition is scheduled…” C.C.P. § 2025.410

(emphasis added).

Here, neither Defendants nor DeJoria served any valid or timely objections to Plaintiff’s

deposition notice. Defendants’ counsel Merino mailed Plaintiff an Objection to Notice of

Deposition of DeJoria (the “Objection”) on September 23, 2021 – one day after DeJoria’s

deposition was properly noticed and he failed to appear. Ambrose Decl. ¶ ¶ 22-24. Merino’s

Objection was served with a “Proof of Service” dated September 21, 2021, however the shipment

tracking information attached to the Objection and Proof of service state clearly that it was sent on

September 23, 2021. Id. In addition, the purported Objection was not served on Plaintiff’s counsel

by email even though the parties have an electronic service agreement and routinely serve each

other by email.2 Id. ¶ 2, Ex. A, ¶ 23, Ex. V.

Even if the Objection was truly served on September 21, 2021, and all indications are that it

was not, it still fails to satisfy the timeliness requirements of Section 2025.410, that requires an

objection to be served within three calendar days of the deposition date. As Defendants failed to

file a timely objection to DeJoria’s deposition, they waived any objections. The Court should thus

compel Defendants to produce DeJoria for deposition and produce the documents and records

attached to his deposition notice.

B. DeJoria is a managing agent of Defendants ROK Stars and ROK Drinks and

thus must appear for deposition

Even though Defendants have waived any argument to DeJoria’s properly noticed

deposition by failing to serve a timely objection, Defendants’ contention that DeJoria is not a party

affiliated witness does not withstand any scrutiny. Rather, as shown by Defendants’ internal

documents and public statements, the testimony of ROK Drinks’ former president Alison Kennedy,

and Plaintiff’s declaration, DeJoria is involved in every aspect of management at both ROK Stars

and ROK Drinks. California courts routinely look to federal courts in analyzing the issue of

whether a deponent is a managing agent under C.C.P. § 2025.280(a). Lopez v. Watchtower Bible &

Tract Society of New York, Inc., 246 Cal.App.4th 566, 601 (2016). Courts consider the following

factors in determining whether a person is a managing agent: (1) whether the individual is invested

with general powers allowing him to exercise judgment and discretion in corporate matters; (2)

whether the individual can be relied upon to give testimony, at his employer’s request, in response

to the demand of the examining party; (3) whether any person or persons are employed by the

corporate employer in positions of higher authority than the individual designated in the area

regarding which information is sought by the examination; (4) the general responsibilities of the

individual respecting the matters involved in the litigation. Elasticsearch, Inc. v. GmbH, 2021 WL

1753796 at *1-2 (N.D. Cal. May 4, 2021) (finding the potential deponents were managing agents

where they had authority over Defendant and power regarding subject matter of litigation).

In determining whether a person is a party’s managing agent, Courts focus on whether the

individual is invested with general powers allowing him to exercise judgment and discretion in

corporate matters and the general responsibilities of the individual respecting the matters

involved in the litigation.” Id (emphasis added). Shareholders are managing agents when

“responsible for initiating” the “disputed purchase.” Resort Properties of America v. El-Ad

Properties N.Y. LLC, 2008 WL 2741131 at *3 (D. Nev. 2008) (holding “owner and majority

shareholder” was “clearly a managing agent” of Defendant corporation and finding where party

offers to “conduct the deposition via video conference,” it is not unduly burdensome.).

Here, despite Defendants’ assertion that “DeJoria has no role in the dispute,” DeJoria’s role

as a managing agent is clear. Ambrose Decl. ¶ 10. DeJoria was deeply invested with general

powers which allowed him to exercise direct judgment and discretion in corporate matters directly

affecting the matters with respect to: (i) The MOU between Plaintiff and Defendants that is at the

heart of this action; (ii) the provision of ROK Stars shares promised to Plaintiff; (iii) meetings,

business decisions, and financial decisions relating to Plaintiff’s employment with ROK Drinks, and

Plaintiff’s Graffiti Wine Brand, which was owned by ROK Drinks and/or ROK Stars; and (iv) the

decisions of Defendants Kendrick, ROK Stars and ROK Drinks, all of which took orders from and

were managed by DeJoria. Id. ¶ ¶ 10-19. Moses Decl. ¶ 2-9.

DeJoria is also in the position of highest authority on the subject matters of information

sought. DeJoria gave instructions directly to Defendant Kendrick, who signed the MOU,

specifically on matters at the heart of this litigation, including whether Kendrick had permission to

sign the MOU, or to terminate the MOU. Ambrose Decl. ¶ ¶ 12-19; Moses Decl. ¶ 2-3, ¶ 8.

DeJoria had authority over the funds tied to the MOU, and whether Defendants ROK Stars and

ROK Drinks could pay the consideration to Plaintiff contemplated in the MOU, including the cash

payments and $250,000 of ROK Stars stock. Ambrose Decl. ¶ ¶ 11, 14, 16-19; Moses Decl. ¶ ¶ 2-7.

Put simply, DeJoria exercised near complete control over whether the MOU could or could not be

executed, and whether it could be performed. Moreover, it is clear that DeJoria was responsible for

initiating the disputed agreement between Plaintiff and ROK Drinks. Ambrose Decl. ¶ ¶ 12-14, 16-

19; Moses Decl. ¶ 2-4. Thus DeJoria is a managing agent of ROK Stars and ROK Drinks for the

purposes of this litigation. Elasticsearch, Inc. v. GmbH, 2021 WL 1753796 at *1-2 (N.D. Cal. May

4, 2021); Resort Properties of America v. El-Ad Properties N.Y. LLC, 2008 WL 2741131 at *3 (D.

Nev. 2008).

Plaintiff has also offered to perform a video deposition of DeJoria, further identified the

planned scope clearly and concisely, and offered to limit the duration of the DeJoria deposition. The

burden on DeJoria would thus be extremely limited. Ambrose Decl. ¶ ¶ 2, 5, Ex. A, Ex. B.

Plaintiff therefore asks this Court to compel Defendants to produce their managing agent

DeJoria for deposition and to produce the documents described in the deposition notice attached to

the Ambrose Declaration as Exhibit B.Plaintiff respectfully asks that the court grant this motion and order

Plaintiffs to produce DeJoria for deposition within twenty days from the date of the hearing.

JUST THINKING OUT LOUD….IF JOHN PAUL DEJORIA’S THREE DEAD PARTNERS WENT THROUGH SIMILAR?

PAST BLOG…BACARDI AND JOHN PAUL DEJORIA’S LAWYERS, WERE CIRCLING LIKE VULTURES, LESS THAN TWENTY FOUR HOURS AFTER HIS PARTNER, IN PATRON, WAS FOUND AT THE BOTTOM OF THE STAIRS….(PAST BLOG)

CAUSE OF DEATH! OR SHOULD I SAY, CIA, CAUSE OF DEATH…..HEART ATTACK!

P.S. JOHN PAUL DEJORIA FUNDED “THE SOUND OF FREEDOM”, BAD GUY, PLAYING GOOD!

6 Comments

  1. Flpatriot says:

    Wondering why John Paul seems to be flying under white hat radar. It seems he’s been implicated and/or caused harm to many people, not the least of which is you and your children, but harm to many children, people, complicit or tied to deaths, money laundering, etc etc. Hes a famous figure ( or was in the 80’s) and although is not as much in the spotlight as he once was, still needs his day of reckoning. As you have revealed, the trail of destruction left behind by many elite puppets that stand behind an anonymous curtain of money, still need to be taken down. I pray my friend for your sake and that of your children that this demon’s time is short as well. I pray to Jesus that he will solve this in His due time, according to His will, and free you. In the meantime, keep helping others as you are. Your job is so important! ❤️✝️

    • Tracy Zona says:

      HE IS A SLEEPER…ONE OF THE WORST! WHAT KIND OF MAN, A BILLIONAIRE, WOULD HAVE HIS GANG, TERRORIZE, LEGALLY ABUSE, THREATEN AND HARASS A WOMAN…WHO HAS EVEN LOST HER CHILDREN, EVERYTHING, TO THIS WORLDWIDE EVIL? (ME) IT MAKES ME SICK TO CONTINUE TO WATCH HIM USE HIS SAME PATTERN OF DESTRUCTION ON GOOD PEOPLE, OVER AND OVER, AGAIN. THANK YOU…..AND HIS PARTNER IN FULL ON CRIME, JONATHAN KENDRICK, FLED ENGLAND, A CRIMINAL, WITH A CRIMINAL HISTORY, OF MULTIPLE FRAUDS, ONLY TO WIND UP IN LA….WORKING AND DOING JOHN PAUL DEJORIA’S EVIL, DIRTY WORK, FOR A PERCENT. HE IS TERRORIZING U.S. CITIZENS AND HE IS NOT EVEN ONE…..CHECK OUT WHAT HE DID TO SELL CONTAMINATED BEER TO THE PUBLIC…AS YOU KNOW THIS EVIL LOVES TO POISON US….

      ~ ROK’s Malfeasance

      38. In the course of providing these services, Plaintiff observed ROK engaging in a variety of misconduct:

      a. Kendrick directed Plaintiff to give away thousands of cases of expired ABK beer owned and/or under the control of ROK Imports, Inc. Plaintiff refused because California law prohibits distributors from giving away alcoholic beverages, and therefore complying with Kendrick’s order would subject Plaintiff to criminal penalties and the loss of his liquor license. Subsequently, at Kendrick’s instructions, ROK employees gave away the expired beer, primarily to people without liquor licenses.

      b. Kendrick directed Plaintiff to relabel expired ABK beer imported from Germany, which was owned and/or under the control of ROK Imports, Inc., to hide the expiration dates. Plaintiff refused because such relabeling is illegal, and therefore complying with Kendrick’s order would subject Plaintiff to criminal penalties and the loss of his liquor license. Subsequently, at Kendrick’s direction, ROK employees obtained new labels, relabeled the expired beer, and sold this beer to various alcohol distributors. A true and correct copy of one such label is attached hereto as Exhibit E.

      c. Contrary to Plaintiff’s advice, ROK Drinks sold ABK Beer to retailers and distributors at different prices, in violation of the regulations of the California Department of Alcoholic Beverage Control, including Title 4, Division 1, Article 15 of the California Code of Regulations.

      d. ROK Drinks instructed Plaintiff to assist in organizing an event at its warehouse in the City of Commerce in October 2017, at which event alcoholic beverages would be sold directly to consumers without an appropriate liquor license. Plaintiff refused to assist in ROK Drinks’ illegal conduct with respect to this event. However, the event took place anyway and ROK sold its alcohol products directly to the general public inside its alcohol warehouse in violation of state law.

      e. In late 2017, ROK Drinks requested that Plaintiff ship Bogarts Spirits directly to consumers that purchased these alcoholic beverages through the website http://urbandaddy.com, with the shipments being made from ROK Drinks’ Culver City offices using ROK Drinks’ and ROK Imports’ FedEx accounts. Because shipping alcoholic beverages directly to consumers violates various California laws, Plaintiff refused to assist ROK Drinks after informing ROK Drinks that this conduct was illegal.

      39. When Plaintiff brought these illegal activities to the attention of ROK management, they ignored and/or threatened him, based on his alleged nondisclosure obligations to ROK. ROK then began limiting Plaintiff’s duties and excluded Plaintiff from important ROK business and beverage product meetings.

      40. In addition, Plaintiff routinely witnessed Kendrick and other ROK management deploying racist insults against various ethnic groups, including Mexican, Indians, Native Americans, and African Americans, as well as chauvinist statements against women. ~

      And of course my abusive ex husband Richard Zona Jr. HELPED THEM TO GANGSTALK, THREATEN, TERRORIZE, AND HARASS ME…and EVEN GOT OUR CHILDREN INVOLVED WITH THIS PURE EVIL.

      BTW….PER PAST BLOGS JONATHAN KENDRICK AND JOHN PAUL DEJORIA, GO WAY BACK IN ENGLAND, COMMITTING FRAUDS, IN THE UK TOGETHER. (DEJORIA’S DIAMONDS, PAST BLOG)

  2. Laur says:

    Let’s not forget his meat delivery!

  3. Kingdom Warrior says:

    Tracy what’s up with Joe Rogan?

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