ILENA ROSENTHAL, Plaintiff in Pro Per

1380 Garnet #444

San Diego, California 92109

(858) 270-0680

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN DIEGO

 

ILENA ROSENTHAL

in Pro Per

Plaintiff,

v.

AMERICA-ON-LINE; McGHAN

CORPORATION, INAMED CORPORATION; PATRICK J. O'LEARY, SUSAN SCHAEZLER, ETC. INFORMATION SERVICES; and

DOES 1 to 20, inclusive

Defendants.

CASE NO. GIC739307

SUPPLEMENTAL DECLARATION OF ROGENE SCHORER IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION TO STRIKE AND REQUEST FOR ATTORNEY'S FEES

 

TELEPHONIC

NO APPEARANCE REQUIRED

Date: August 11, 2000

Time: 2:00 p.m.

Dept.: 60

Judge: Honorable William C. Pate

Complaint Filed: Nov. 24, 1999

 

I, ROGENE SCHORER, declare as follows:

    1. I am submitting this declaration in support of the Plaintiff’s Opposition to Defendant’s Motion to Strike and Request for Attorney’s Fees. I have personal knowledge of the facts set forth below. If called upon to testify, I could and would competently testify to the facts set forth herein.
    2. The purpose of this letter is to document certain experiences I have had on-line with defendants Susan Schaezler, "Mplnt" (O’LEARY) and other entities.
    3. I was invited into the BIS group by Susan SCHAEZLER. Supposedly this was to be a group where we could share information privately about the effects breast implants were having on us. I was told that "mplnt" (O’LEARY) was a caring professional who was trying to help women with their problems. He continually refused to identify himself despite numerous requests to do so. He claimed that he was not a manufacturer.
    4. Throughout this time, Susan Schaezler encouraged women to share private information with her. Susan created a list of rules by which the group was to be run. The rules applied to all but Susan. She berated anyone who did not follow her rules. I left because I saw a repeated pattern of accusations against certain individuals, including Ilena Rosenthal. Susan actively tried to berate Ilena and ruin her reputation in every imaginable way. Mplnt supported Susan's accusations at every opportunity.

I declare under penalty of perjury under the laws of the State of California on this 31st day of July, 2000, that the foregoing is true and correct.

 

By: _________________________________________

ROGENE SCHORER