SIN Cans RICHARD T. BOWLES (#46234) DAVID A. GOLDSTEIN (#319394) Bowles & Verna LLP 2121 N. California Bivd., Suite 875 ‘Walnut Creek, California 94596 Telephone: (925) 935-3300 Facsimile: (925) 935-0371 Email: rbowles@bowlesverna.com Attorneys for Plaintiffs NEW U LIFE and ALEXY GOLDSTEIN IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA NEW U LIFE and ALEXY GOLDSTEIN Case No. MSC19-00323 DECLARATION OF DEBRA AMBROSE IN SUPPORT OF OPPOSITION TO SPECIAL MOTION TO STRIKE THE COMPLAINT Plaintiffs, v. GEORGIA HARGETT and DOES 1 through 10, inclusive, Defendants. |, DEBRA AMBROSE, declare as follows: Tam an Independent Marketing Consultant (“IMC”) for New U Life. In my work with ‘New U Life, | worked with Georgia Hargett (“Hargett”). 2. I was Hargett’s sponsor, meaning that | brought her into the company. We were on the same team and we worked closely. 3 Ut tion of social media is key to suecess as an IMC. Hargett had trouble with technology and could not handle her social media accounts on her own. Hargett provided to me all of her relevant account passwords and expressly granted me permission to access her social media accounts and website, including her Facebook/Facebook Messenger account, With access to Hargett’s accounts, I was able to help her manage that technology, which was a great benefit to her as an IMC. 1 DECLARATION OF DEBRA AMBROSE IN SUPPORT OF OPPOSITION TO SPECIAL MOTION TO STRIKE THE COMPLAINT4 s 1 declare under penalty of perjury under the laws of the State of California Hargett never revoked her permission to me to aveess her social media accouns, ‘While Hargett was sll working as an IMC for New U Life, heard from other IMCS that she was tling people hat New U Life CEO Alex Goldstein “Golesi” was a feud and that he had seven Social Security number. Whea I confiontd Hargett about those rumor, she denied that she hal said anything negative about Goldstein, Subsequent tomy contonting Harget about the rumars ta she was making negative remarks about Goldstein, discovered messages on her Facchook Messenger account between Hargett and several other people where Hargett was saying negative things about New U Life and people affiliated with New U Life, including Gols, 1 took sereenshos of several of hose messages and provided them fo New U Lite comet. Some of those messages were atached othe Compl in this lawsuit have never gained unauthorized access to Harget's accounts, at the foregoing is true and correct. Executed this_22 day of Moy, 2019, at 1644 Anchors Way, Ventura, CA93001 Deere Antore DEBRA AMBROSE