Date: April 13th, 2014 12:35 PM
Author: vibrant chestnut address
Exhibit M: From Ciolli's deposition, taken March 2, 2008, 9:05 am to 1:04 pm, Orlando, Florida.
[p. 26]
Q Okay. Do you have a general sense of how many users use the change user name feature?
A I don't know how many people actually use it, no.
Q Have you ever changed your user name?
A No
Q So you only have one user name on the site?
A You mean user name or alias?
Q I'm sorry, alias?
A Alias, no. I should clarify. Immediately when I registered my account, I registered my account with the Anthony, but I immediately changed it to Great Teacher Onizuka because that's the alias I wanted to have. You can't register a user name that has spaces in it.
Q Do you have anyother -- any other aliases?
A No.
Q So your two aliases are Anthony and Great Teacher Onizuka?
A Yes.
[p. 27]
Q Okay.
A I should clarify. I have several additional aliases that I never used but I registered to prevent other people from impersonating me on AutoAdmit.
Q Okay.
A Because there had been other users who would post messages claiming to be me. They, perhaps, post -- for example, they take like, for example, one individual who has their name Great Teacher Onizuka period, had a period at the end. And people -- you would make posts people believe -- to prevent that, I registered various other aliases under my account to prevent other people from registering them and trying to impersonate me, but I never actually posted messages with those aliases. But the only alias I actually ever used was Great Teacher Onizuka.
Q Okay. And how many other aliases do you have, just the ones you used to prevent?
A Yes, just those. I don't know how many, I would guess maybe about ten.
Q And those are all just --
A I never made posts with them.
[p. 33]
...I belive he used the e-mail account AHWIAB@gmail.com, and as you can tell from the e-mail conversation I provided. And, I believe, that DRACULA used the e-mail DRACULAESQ@gmail.com. And other than that, I don't believe I know anyone's e-mail address.
Q What was the -- can you say the A horse walks into the bar e-mail again?
A AHWIAB@gmail.com.
Q How did you come to know that A horse walks into a bar, their name was Ryan?
A He sent me an e-mail, and he signed it Ryan.
Q Other than receiving the e-mail, do you have any other knowledge of that name?
A I met a person who claimed to be A horse walks into a bar at an AutoAdmit meet-up in June. And at that meet-up, he identified himself as Ryan, but he did not provide a last name.
Q What was this meet-up?
A It was just a social gathering of people who posted on the AutoAdmit message board.
Q And where did it take place?
A In Washington, DC.
Q Who else was there?
[p. 34]
A There were some, I can't remember everyone who was there, but, I believe, there was -- I believe, Wi1l Rothwe1l attended.
Q Can spell that for me?
A W-i-l-l, R-o-t-h-w-e-l-l, Cassidy McNamara, and there are various other individuals, but I don't remember them by their real names.
Q What were their user names?
A User names were, I believe, Adalia.
Q Can you spell that?
A A-d-a-l-i-a, Annie Econ, A-n-n-i-e underscore, E-c-o-n, and Andy Grew@l had attended briefly for maybe 20 minutes.
Q I'm sorry. You mentioned someone after Cass1dy. You said Cassidy and there was another real person?
A Cass1dy McN@mara.
Q McN@mara?
A Yes.
Q How would you spell that?
A M-c-N-a-m-a-r-a.
Q And who was the other real live person you knew there?
A I just gave you the list.
Q I can -- Wi1l Rothwe1l, that was the name?
[p. 35]
A Yes.
Q And what are Cass1dy -- what is Cassidy McNamara's alias?
A jane hoya.
Q What is Will Rothwell's alias?
A Mind the gap 76.
Q And Andy Grewal's?
A I don't know what name he currently uses
Q What names has he used?
A I believe he might have used RedSox7 uses now, if he has any at all.
Q And when did this take place?
A I don't remember the exact date, I think it might have been on or around June 20.
Q 2007?
A 2007, yes.
Q In Washington DC?
A Yes.
Q What was the setting?
A It was a bar. I don't remember the name of the bar.
Q Okay. Which party of DC?
A Northwest.
[p. 49]
Q So this would have been Fall 2007?
A Yes
Q Did he say he was a current student there or starting?
A Would be starting.
Q Have you ever -- since the meet-up in DC, have you had any other contact with Ryan or A horse walks into a bar?
A The only contact I had with him were e-mails that I provided to you. So if there were any e-mails dated after the meet-up, then I guess there was additional contact. But other than that, not to my knwoeldge.
Q What else do you know about Ryan?
A I don't know anything else. I believe he used the AOL Instant Messenger screen Atlas429.
Q Atlast is spelled, A-t-l-a-s?
A Yes.
Q And the No. 429?
A Yes, I believe it was 429.
Q So you had instant messenger conversations with him?
A Occasionally before meet-up.
Q Okay. And what did you discuss?
A Just the meet-up, and that it was going to
[p.52]
[Q]... Talking again about Exhibit No. 2, looking at the first line of Exhibit No. 2, there is an alias that is a colon and the letter capital "D".
A Yes.
Q What do you know about that person?
A I know that they used the AOL Instant Messenger screen name Que Tarantino.
Q Spell that for me?
A Q-u-e, T-a-r-a-n-t-i-n-o.
Q And what else do you know about him?
A I believe he attended the Texas A&M University, then transferred to University of Texas -- or at least that's what he said, the AOL Instant Messenger at some point in the past.
Q You had AOL Instant Messenger conversations with him?
A Yes.
Q Roughly how many?
A I honestly don't know the years ago, 2004, 2005.
Q More than 20?
A I honestly cannot speculate on that. I don't know.
Q Okay. What else do you know about them?
A I don't know anything else about him.
[p. 68]
[Q] Dirty Nigger. What do you know about that user?
A Well, from his name, I would assume he's a racist. But other than that, I don't know anything about him.
Q Do you know where they live?
A No.
Q Have you ever had any communications with them?
A No.
Q E-mail or IM conversations?
A No.
Q What was their representation on the board?
A I do not know.
Q The -- this is something of a -- someone posts frequently?
A I have no idea. I'm not familiar with that user name.
Q Do you have any reason to believe they know [DOE II] or (DOE I] ?
A I have no idea.
Q Turning to No. 11, this is the user name, the user who uses the alias DRACULA. What do you know about DRACULA?
A I know you mentioned earlier his gmail
[p. 69]
address, and I believe he also used the AOL Instant Messenger name DRACULA, ESQ.
Q DRACULA, ESQ.
A Yes.
Q Can you spell that?
A D-r-a-c-u-l-a, E-s-q.
Q And the e-mail address was draculaesq@gmail.com?
A Yes.
Q What else do you know about the person?
A I know nothing else about this individual.
Q You had e-mail exchanges with him?
A I believe he had been CCed on one of my on e-mails I had with A horse walks into a bar, and he had contacted me on AIM, I believe, once, too, after the lawsuit was filed to ask where to go for legal representation. I believe I referred him to EFF. And other than that, I have not had any conversations with him or know any other information about him.
Q Do you know if he contacted EFF?
A I do not know.
Q EFF is the Electronic Frontier Foundation?
A Yes.
Q Does -- how many instant messenger
[p. 112]
Q Roughly age?
A Late 20s, early 30s.
Q How about bothered, who is bothered?
A I don't know his name.
Q Was he a student?
A I think he was a teacher.
Q Where was he a teacher?
A I really -- I really don't know. I think maybe New Jersey. He didn't provide much personal information.
Q Is he a high school teacher?
A I have no idea. This was four years ago.
Q Any reason to think any of these people are defendants?
A No.
Q Know any of the defendants?
A No.
Q So turning back to Doug1as Phi1labaum, you've had e-mail communications with him?
A No.
Q I'm sorry, your lawyer has.
A My attorney.
Q But you've IM'd with him at SUA SPONTE 23?
A Yes, to get the Top 14 contest shut down.
[p. 113]
Q Roughly how many times did you IM with him?
A I really don't know. I guesstimate maybe three or four times in total during that period, but I really don't know.
Q Did you discuss anything other than the T14 site?
A I don't believe so.
Q Did you discuss [DOEll] and, [DOE I]?
A I do not recall.
Q Is AnthonyCiolli your instant messenger user name?
A Yes.
Q Your first name and last name with no spaces?
A Yes.
Q And is halawaddin Jarret Cohen's user name?
A Yes.
Q Is that spelled, h-a-l-a-w-a-d-d-i-n?
A Yes.
MR. BERKOWITZ: Let's take a break now to change the tape.
[END]
http://www.autoadmit.com/thread.php?thread_id=880977&forum_id=2#10362799
(http://www.autoadmit.com/thread.php?thread_id=2541144&forum_id=2#25375670)