MOTION TO DISMISS FOR LACK OF JURISDICTION - AFFIDAVIT - EXHIBITS (Including The 10 Reasons I Left Gorilla Productions & Gorilla Music's 10 Ways To Have a Great Show) - DEFENDENTS' MOTION TO STAY


No comments in this section. Wade nailed all the points better than I ever could. Just read it for our reply.

This is the affidavit I did. There doesn't need to be any extra comments.
Oh, comments other than...check out all those Gorilla myspace sites and tell me they didn't use them to spam email bands!
All these exhibits are available on other pages so I won't list them all.
This is about the Google controversy and how I really don't have enough smarts to control internet searches on Google.

This is the Lackluster myspace page: The band Gorilla acused me of making up so I could send them a nasty email, after they sent me an invitation to a battle of the bands, that is.



There was a ton of this but I will list the main pages we used as evidence to prove our case. This page shows some of the big winners of the previous year's battle.

For the record:

Rapper OllieOx broke off from Rock X after posting a brilliant blog that no longer exists.

Junior Doctor is not on Rock X records.

Fight Cloud says: "After extensive thought, we sort of bailed on a record contract offer in 2010 because it didn't seem to be the right fit."

Through the Fall's facebook page is stuck on August 19, 2009 and doesn't seem to on Rock X Records.

This clearly shows that some Gorilla events were called Gorilla Takeovers. Gorilla still claimed defamation for my crack about the giant gorilla head taking over.

This is one of the hand-out sheets you got when you signed up for a Gorilla Music event. We submitted it for this statement:

"So, if you don't think your band can sell at least 30 tickets please do not participate in these events."

Clearly it's about ticket sales.


I absolutely love this one. This is one of the helpful tip sheets every band who plays a Gorilla show receives in the mail with their bundle of tickets.

Having a good show is important so let's check out these 10 ways, shall we?

1. Have everyone in the band sell tickets. Each band member should sell 25.

2. Ask your friends to sell tickets. (Okay, still about tickets but we'll press on.)

3. Go to shows, sell people a ticket.

4. Ask everyone for buying a ticket perhaps?

5. Have a band meeting and force all the members of the band to make phone calls and text to tell them about the show and suggest they buy a ticket. (Still seems mostly about tickets...still waiting for those tips to have a good show!)


6. Okay, this one kills me. Emergenza uses this handy tip also. So you put on your own show/party (with free food and drinks no less!) and then get your "guests" to buy tickets. Isn't this getting kind of expensive? And I'm going to say it...if you can put on your own show, why would you need Gorilla Music?

7. Use Myspace and set up a Paypal site to sell tickets.

8. Assemble a street team to sell your tickets (isn't that like "Way #2 - Ask your friends to sell tickets"?).

9. Set up a car pool and drive people to the show. Don't most bands have enough trouble just getting themselves to the show? Now they have to set up carpools?

10. Finally...put on a great show.

So the 10 ways are all ticket selling and then...put on a great show. This paper should have been entitled "10 Ways to sell Gorilla Music Tickets".

Anyway, it certainly was good proof that ticket sales are the more important feature of Gorilla events.

Again, they want all bands to sell at least 30 tickets or they won't be asking you back.


This is the blog Gorilla Liz was sued over (Case #CV-09-706282). Since it was public record (in fact, the case is available from the Cuyahoga Court if you live in the area and want to go over there and check out the entire thing - they'll charge you a small fee by the page), we felt this was evidence (Reason #8) that Gorilla Reps were getting thousands of emails from unhappy bands. This proved that it had been going on many months before Gorilla attempted to blame me for all their "hate" emails. This blog is eye-opening.

The band Liz is concerned about, Dangerous New Addiction, has been on hiatus since Feb. 17, 2011. Their facebook post reads:

NEWS: The band is on an indefinite hiatus with the absence of Lance Dowdle.

Dangerous New Addiction won the $25,000 contract with Rock X Records and headlined the Cleveland Music Festival. At that show (and before they actually signed the Rock X contract) guitarist Lance Dowdle was selected to join another band that Gorilla associate Jeff Blue manages, Emphatic. Great for Lance, not so great for the rest of Dangerous New Addiction.




This is our motion to stay, which means I could keep my website going while the matter was being argued. The judge granted this stay.