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Marc J. Randazza, NV Bar # 12265

Ronald D. Green, NV Bar # 7360

J. Malcolm DeVoy, NV Bar #11950

Randazza Legal Group

6525 W. Warm Springs Rd., Ste. 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

ecf@randazza.com

Attorneys for Plaintiff,

Liberty Media Holdings, LLC

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

Liberty Media Holdings, LLC, a California 

Corporation

Plaintiff,

vs.

FF Magnat Limited d/b/a Oron.com; Maxim 

Bochenko a/k/a Roman Romanov; and John 

Does 1-500,

Defendants.

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Case No.: 2:12-cv-01057

PLAINTIFF’S OPPOSITION TO 

DEFENDANT MAXIM BOCHENKO’S 

MOTION TO DISMISS: REQUEST FOR 

JURISDICTIONAL DISCOVERY

Pursuant to Fed. R. Civ. P. 7(b)(1), Plaintiff Liberty Media Holdings, LLC, by and through 

its undersigned counsel and upon the grounds set forth below, respectfully opposes Defendant 

Maxim Bochenko’s Motion to Dismiss and moves the Court for an order allowing the Plaintiff to 

conduct limited discovery on the personal jurisdictional issue raised by Defendant Maxim 

Bochenko’s Motion to Dismiss. This Opposition is made and based upon the attached 

memorandum of points and authorities, the papers and pleadings on file in this action, and any oral 

argument permitted by this Court.

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2

Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

I. INTRODUCTION

The instant action arises from the willful infringement of Plaintiff’s works by Defendants. 

The members of the website Oron.com directly infringed upon Plaintiff’s works; the owners and 

operators of Oron induced the infringement of their users, paid their users for the infringement, and 

otherwise encouraged and facilitated the infringement for their financial benefit.

Not only has Defendant Bochenko been compensated handsomely by FF Magnat Ltd. for 

his assistance in inducing the infringement, but it appears that Defendant Bochenko is also a direct 

infringer of numerous companies’ works. Defendant Bochenko denies any connection whatsoever 

to both FF Magnat Ltd. and to Nevada. However, Plaintiff has received an unsolicited box of 

documents from an individual named Oleg Karapetian. This box of documents contains several 

items showing Maxim Bochenko using the email address “mainroman@gmail.com” for his 

personal use. Exhibits 50-52, 54, 56, 60. Other documents demonstrate Bochenko utilizing the 

same email address to carry out correspondence with payment processors tied to Oron. Exhibits 6, 

7, 9, 12-14, 23, 35, 41-43. Further, these documents contain emails sent from 

“support@oron.com” and signed “Maxim.” Exhibits 41-43. Defendant also appears to utilize the 

email address “main_max@mail.ru” and has a PayPal account tied to that email address. Exhibit 

44. The package also contained a screen shot of a private message sent on “kinkyfetish” message 

boards from user “mainroman.” Exhibit 40. In this message, the user identifies himself as 

“Roman Romanoff” an individual who works “at ORON as a development manager.” Id. The 

message goes on to request that Oron be made an allowed host on the message board and offers the 

operators of the board 5% of all sales made via links found on the forum. Id. The user lists the 

Skype account “mainroman” or the email address “support@oron.com” as means of contact to 

respond to this offer. Id. In what appears to be a Gmail search of mainroman@gmail.com for 

“Bochenko,” several pieces of correspondence containing Bochenko’s name and Florida addresses 

are displayed. Exhibit 60. Additionally, several of the documents appear to show Bochenko 

corresponding with individuals and offering them payment for posting Oron links on message 

boards. Exhibits 22, 24-26, 30. The sixty-five documents provided to Plaintiff by Mr. Karapetian

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

demonstrate a network of interconnections between Oron and Bochenko. They are outlined in the 

table below.

Exhibit Description Relevancy of Document

1 Merchant Questionnaire for 

amsVISA

Demonstrates that Oron was negotiating to get 

Oron a Nevada based payment processor. Lists 

“Serge Kozlowsky” as contact person.

2 Email sven@oron.com to 

support@oron.com and 

mainroman@gmail.com

Email from “Sven – Oron.com Marketing 

Manager” to “Oron.com – Support” and 

“Roman Romanov” which opens with “Hello, 

boss.” This email lists a number of potential 

places to advertise Oron, including specifically 

listing U.S. banner ad prices. Roman Romanov 

then responds requesting the password for the 

WJunction, and apparently receives it, as he 

later informs Sven of the changed password.

3 Proposal for Banners from 

Wasserwerfer

Banner advertisements commissioned by Oron 

representatives display information about a 

user’s ability to profit from the service, not 

about long-term, reliable data storage

4 Email FriendFinder Networks 

to mainroman@gmail.com

Identifies as “Roman Romanov” with 

FriendFinder representative bartering about 

banner ads on pornbb.org

5 Leaseweb B.V. Invoices Invoices are addressed to a “G. Maksim” 

6 Email AlertPay to 

mainroman@gmail.com

Chris Tisdall from AlertPay sends file titled “FF 

Magnat Limited Acct history” to Roman 

Romanov, indicating that email address is used 

for FF Magnat business. Email specifically 

asks questions for “a friend” in the U.S. about 

payment options.

7 Email chain between AlertPay 

and mainroman@gmail.com

Melissa Andrews from AlertPay emails with 

Roman Romanov while Chris Tisdall is away. 

Roman refers to “our account 

(support@oron.com)” in the email and 

references two different incoming wires of over 

$40,000.

8 Email mainroman@gmail.com

to zara256@gmail.com

Roman Romanov emails seven pages of 

Oron.com links to this address with no subject 

or instructions.

9 Email AlertPay to 

mainroman@gmail.com and 

support@oron.com

Chris Tisdall of AlertPay sends DMCA Notices 

of Copyright Infringement to both Oron Support 

and Roman Romanov. Roman responds saying 

that he believes the issue is resolved after 

contacting the rights holder.

10 Email support@oron.com to 

mainroman@gmail.com

Oron sends to Roman Romanov the details on 

how to pay its Leaseweb bill of 71.860,83 

Euros.

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Exhibit Description Relevancy of Document

11 Email from WeservIT to 

mainroman@gmail.com

Raoul Vos at WeservIT forwards DMCA 

Notices of Infringement on forumophilia.com to 

Roman Romanov. Vos also states that the 

rights holder should contact user “papillon” on 

the forum to get items taken down.

12 Email from AlertPay to 

mainroman@gmail.com

Chris Tisdall to Roman Romanov detailing the 

frozen funds for the “account 

support@oron.com”

13 Email from AlertPay to 

support@oron.com and 

mainromain@gmail.com

Chris Tisdall emails Roman Romanov and the 

Oron account forwarding a DMCA Notice of 

Copyright Infringement from a rightsholder 

with lists of Oron links.

14 Email AlertPay to 

mainroman@gmail.com

Email from AlertPay disclosing a $5,200.00 

USD payment from Oron.com

15 Email from sven@oron.com to 

mainroman@gmail.com

Sven, identified as Oron’s Marketing Manager 

forwards to Roman Romanov a request he 

submitted to support@digitalpoint.com

requesting deletion of old account in favor of 

new official account for Oron support.

16 Email from sven@oron.com to 

mainroman@gmail.com

Sven forwards further correspondence regarding 

account at Digital Point forums.

17 Email from Wholly 

Productions to 

mainroman@gmail.com

Email from Wholly Productions with list of 

links on fileserve.com to be taken down for 

infringement.

18 Email sven@oron.com to 

mainroman@gmail.com

Email from Sven attaching potential banner 

advertisements for Oron.

19 Email sven@oron.com to 

mainroman@gmail.com

Email from Sven regarding advertising banners 

on sk-down, serial-hun, WJunction, warez-bb, 

hong-fire and akiba-online.

20 Email sven@oron.com to 

mainroman@gmail.com

Email from Sven attaching paper from 

webdesigner regarding potential Oron banner 

advertisements

21 Email sven@oron.com to 

mainroman@gmail.com

Email from Sven attaching photographs of 

business people that are free for their use.

22 Email 

sexysuzy2000@hotmail.com to 

mainroman@gmail.com

Email from “Sexy Suzy” to Roman Romanov 

regarding posting on pornbb. Romanov offers 

Sexy Suzy “10 cents per post” and specifies that 

content should be on Oron.

23 Email AlertPay to 

support@oron.com and 

mainroman@gmail.com

Chris Tisdall emails to explain issue with a 

missing withdrawal from the account.

24 Email alan0123@hotmail.com

to mainroman@gmail.com

Email from “Alan Gbt Trinidad” to Roman 

Romanov discussing payment for posting on 

various websites. Roman copies both Alan and 

Sexy Suzy on an email attaching a file named 

“ADMIn (1st Job) PICS + Oron Links.txt.” 

Romanov instructs users in methodology of 

posting and says he will compensate them for it.

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Exhibit Description Relevancy of Document

25 Email alan0123@hotmail.com

to mainroman@gmail.com

Alan addresses Romanov as “Admin” and 

discussing pornbb issues with posting Oron 

links. Alan suggests that Romanov “ask 

another Mod.” Furthermore, this email 

identifies mainroman@gmail.com as “ADMIN 

Pornbb Roman Russia.”

26 Email alan0123@hotmail.com

to mainroman@gmail.com

Romanov sends an email identifying Oron and 

RapidShare accounts to use for posting on 

message boards. Email further identifies 

several usernames and passwords to use for 

posting on pornbb. Alan emails Romanov to 

discuss payment method.

27 Email mainroman@gmail.com

to oxygene.oxygene@ya.ru

Email attaches text file named “Thread list.” 

28 Email mainroman@gmail.com

to mainroman@gmail.com

Romanov sends himself two text attachments 

titled “ORON work” and “BBWork.”

29 Email mainroman@gmail.com

to mainroman@gmail.com and 

mainroman@yahoo.com

Romanov sends himself eight text attachments 

entitled “BBWork,” “domains,” “ORON work,” 

“payments,” “PayPalClaimMessages,” “Posts 

For Vacation,” “Telephoni,” and “sponlogins.”

30 Email mainroman@gmail.com

to capobviously@yahoo.com

Romanov sends an individual an email with a 

link to picsforfriends.com, usernames and 

passwords for RapidShare and Oron, a list of 

forum threads on hentaibb.com and 

planetsuxy.org, and a list of pornbb user names 

with passwords.

31 Email paul.katz@rosebroo.com

to mainroman@gmail.com

Paul Katz contacts Romanov to ask if he 

supports Oron.com.

32 Email mainroman@gmail.com

to mainroman@gmail.com

Romanov sends himself five text attachments 

entitled “BBWork,” “ORON work,” 

“payments,” “PayPalClaimMessages,” and 

“Posts for Vacation.”

33 Email mainroman@gmail.com

to mainroman@gmail.com

Romanov sends himself a PDF entitled 

“Horseback.Riding.For.Dummies.”

34 Email mainroman@gmail.com

to mainroman@gmail.com

Romanov sends himself a text file called “Oron 

Abuses” with a note that this is a new abuse.

35 Email mainroman@gmail.com

to AlertPay

Romanov emails Chris Tisdall at AlertPay 

asking him to fix a wire for “45k$” showing as 

pending.

36 Screenshot of CCBill Account 

Breakdown

Shows multiple transactions from a CCBill 

account, but does not conclusively display who 

owns this account or what the account relates 

to.

37 Contract Signature Page Displays “Roman Romanov” signature with 

listing as “Beneficial Owner” and a Russian 

address. Other spaces in the signature block are 

for “Inese Liepina” as the Director and 

Shareholder for “Mammona Ltd.”

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Exhibit Description Relevancy of Document

38 Email Chain between 

support@oron.com and 

frejtak@red-sky.pl

Oron support email identifies itself as being 

available for contact via Skype at “mainroman” 

or via ICQ at “612-574-040.” Frejtak emails 

Oron to request partnership between Oron and 

FilesTube.com. 

39 Email Google Support to 

mainroman@gmail.com

Google emails Romanov to congratulate him on 

his new gmail address, 

“mnrmn12@gmail.com.” 

40 Private Message on 

kinkyfetish.net from user 

“mainroman”

User mainroman sends a message entitled 

“hello. follow up from ORON.” User identifies 

himself as “Roman Romanoff” and states that 

he works at “ORON as a development 

manager.” User goes on to say that if they 

could be an allowed host, Oron can “offer you 

5% of all sales made via your forum.” User 

requests that they contact him either via Skype 

at “mainroman” or via “support@oron.com 

(mark Attn. Roman Romanoff).”

41 Email support@oron.com to 

dtrommer@micropayment.de

Oron support emails Daniel Trommer in 

German. This email is signed “Maxim.”

42 Email Micropayment to 

support@oron.com

Daniel Trommer replies and opens email with 

“Hello Maxim.”

43 Email chain between 

support@oron.com and 

Micropayment

Trommer and Oron support correspond. Both 

Oron and Trommer identify the individual 

utilizing the support@oron.com account as 

“Maxim.”

44 PayPal notification of money 

sent from LinkShop

Account tied to “main_max@mail.ru” receives 

notice that LinkShop has sent his account 

$3,000 USD. Notation says “Payment to PBB 1 

month.”

45 PayPal Screen for account for 

Fedor Goncharov

Shows PayPal account with a balance of 

“$745.071,14 USD.”

46 Screenshot of Message Board 

post by “MVS”

Shows pornbb WhoIs information listing 

“Fedor Goncharov” and a German address. 

Further shows text of a post user claims was on 

fetish.pornbb (a sub-forum on pornbb.org) that 

claims new “administration” rigged polls to 

make Oron an allowed file host.

47 Email Chain involving 

n.vandegraaf@ocom.com, 

support@oron.com and 

r.lim@leaseweb.com

Vandegraaf (signature block says “Service 

Level Manager LeaseWeb B.V.”) refers to Oron 

support as “Roman” and lists open ticket issues 

with Oron.com. In subsequent emails 

Vandegraaf addresses Oron support as “Mr. 

Maksim.” Oron support identifies Skype 

account as “mainroman.”

48 Text File named “BBWork” Text file includes several IDs and passwords for 

various online platforms, including 

AdultFriendFinder affiliate account, 

adultadworld.com, loadedcash.com, and other 

accounts labeled as “administrative.” Also 

includes messages from “Raveex” regarding 

pornbb.org administrative features.

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Exhibit Description Relevancy of Document

49 Email from 

nooooc@gmail.com to 

mainroman@gmail.com

This email forwards a notice that 

forumophilia.com has inaccurate WhoIs 

information listed. Request to update 

information was originally sent to 

paradontes@ymail.com and then forwarded on 

to nooooc@gmail.com, who finally forwarded 

to mainroman@gmail.com

50 Email from GoDaddy to 

mainroman@gmail.com

GoDaddy email addresses Roman Romanov 

and states that he is the Administrative Contact 

for heinouscomics.net, heinouscomics.org, 

heinouscomics.biz, heinouscomics.info, and 

heinouscomics.mobi.

51 PayPal screen capture of 

Maxim Bochenko account

Screen capture shows PayPal account for 

Maxim Bochenko tied to “main_max@mail.ru.”

52 Email from iTunes to 

mainroman@gmail.com

iTunes Store emails mainroman@gmail.com

receipt for purchase of “Home Sheep Home” 

and lists billing as “Maxim Bochenko” to a 

Ponte Vedra Beach, FL address

53 Text File named “ORON 

work”

Text file contains lists of payments to be made 

to users (including “Raveex”), login 

information for Segpay, PlusFax login, 

domaindiscount24.com login, contact 

information for PayPal Ireland, contact 

information for Key-Systems GmbH, Oron and 

forumophilia IP addresses, purchase of Skype 

online number, AlertPay account information 

labeled “Goncharov,” what appears to be a preformatted message board post with Oron links 

and the title “Incredibly hardcore teen porn 

video!” This text file even lists both “Perfect 

10” and “Liberty Media Holdings” next to each 

other, but does not mention the significance of 

this listing. There are dozens of references to 

pornbb, forumophilia, planetsuzy.org, and other 

message boards devoted to sharing copyrighted 

pornography.

54 Email from Dell Computers to 

mainroman@gmail.com

Order confirmation from Dell to Maxim 

Bochenko, listing payment and delivery 

addresses in Ponte Vedra Beach, FL.

55 Email support@oron.com to 

hocok441@bk.ru

Oron support requests that the webmaster 

contact them urgently via Skype at 

“mainroman.” Oron support goes on to request 

that this Skype name be kept confidential as it is 

“my private Skype.”

56 Email mainroman@gmail.com

to Tulip World

Tulip order to be delivered to Maxim Bochenko 

in Ponte Vedra Beach, FL.

57 Text file entitled “Payments” Text file appears to list several user names, 

identifying which names are banned and 

initials/short hand for the others. Also includes 

link to a section of Oron that appears to be an 

admin screen.

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Exhibit Description Relevancy of Document

58 Text file entitled 

“PayPalClaimMessages”

Appears to be a set of messages used to 

correspond with PayPal regarding Oron user 

complaints to PayPal.

59 Email RapidGator to 

admin@oron.com and 

support@oron.com

Mike Svorov from RapidGator emails Oron 

support asking for contact information. Oron 

support responds with “Skype: mainroman.”

60 Screen shot of search for 

“Bochenko” in 

mainroman@gmail.com

account

Shows several order confirmation, shipping 

confirmations, and other items in 

mainroman@gmail.com addresses to “Maxim 

Bochenko”

61 Email chain between 

mainroman@gmail.com and 

Clips4Sale.com

Romanov emails info@clips4sale.com and 

identifies himself as Maxim Bochenko.

62 Spreadsheet of posts and 

payments

Spreadsheet lists multiple payments to 

main_max@mail.ru and 

mainroman@gmail.com

63 Website Looker Report Report on royalfoam.us website, which lists 

Maxim Bochenko as the owner. Email is listed 

as main_max@mail.ru with an address in 

Jacksonville, Florida.

64 Text filed titled “Posts for 

Vacation”

This text file contains picsforfriends.info image 

links and oron.com links formatted for posting 

on message boards. The posts are numbered 

and separated under headers that appear to be 

user names. File includes at least twenty posts 

for each of four different usernames, one of 

which is “mainroman.”

Based upon the information contained in these documents, Plaintiff seeks leave from this 

Court to conduct jurisdictional discovery to determine: 1) the authenticity of these documents, 2) 

follow-up questions based upon these documents, and 3) the true extent of Bochenko’s relationship 

with FF Magnat Ltd. and Oron. Because Plaintiff has presented factual allegations that suggest, 

with reasonable particularity, the existence of requisite contacts between Defendant FF Magnat 

Ltd. d/b/a Oron.com and the forum state, and because Plaintiff has presented factual allegations 

sufficient to demonstrate the ties between Bochenko and Oron, it is appropriate that this Court 

grant Plaintiff leave to conduct limited discovery, as allowed by the Federal Rules of Civil 

Procedure, to fully determine the nature, extent, and scope of Defendant Bochenko’s contacts with 

Nevada. Plaintiff therefore proposes a 60-day period for such limited discovery and requests that 

the Court allow Plaintiff Liberty an additional fourteen (14) days following the close of such 

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

discovery to submit its full briefing in opposition to Defendant Maxim Bochenko’s Motion to 

Dismiss.

Based upon the information sent to Plaintiff, Bochenko utilizes at least four email addresses 

in conjunction with his work with Oron (mainroman@gmail.com, mnrmn12@gmail.com, 

main_max@mail.ru, and mainroman@yahoo.com); he posts on several message boards (as 

“mainroman” on kinkyfetish.net, as “papillon” on forumophilia.com); he communicates with 

several individuals at payment processing companies on Oron’s behalf (Daniel Trommer at 

micropayment.de, Chris Tisdall at AlertPay); he manages accounts on various online 

communication platforms (“mainroman” on Skype, “23631469” on ICQ); and has accounts with 

hosting providers tied to the mainroman@gmail.com email address (with GoDaddy and Leaseweb). 

Plaintiff seeks leave to send subpoenas to determine the veracity of the information it has been 

provided and the veracity of Mr. Bochenko’s statements made to this Court under the penalty of 

perjury.

II. ARGUMENT

A. Plaintiff Seeks Reasonable Limited Jurisdictional Discovery

1. Standard of Review

When personal jurisdiction is properly challenged under Rule 12(b)(2), the jurisdictional 

question is to be resolved by the Court, with the burden upon the plaintiff to prove grounds for 

jurisdiction exist. “‘Where pertinent facts bearing on the question of jurisdiction are controverted 

... or where a more satisfactory showing of the facts is necessary’ courts should allow for 

discovery.” Wells Fargo & Co. v. Wells Fargo Express Co., 556 F.2d 406, 430 (9th Cir. 1977); 

Marshall v. McCown Deleeuw & Co., 391 F.Supp.2d 880, 882 (D. Idaho 2005). See also Dean v. 

Motel 6 Operating L.P., 134 F.3d 1269, 1271-72 (6th Cir. 1998).

2. Plaintiff Requests Leave to Discover the Scope of Defendant Bochenko’s 

Contacts with the Forum State and with Defendant FF Magnat Ltd.

As Defendant Bochenko points out, the Nevada long-arm statute provides for personal 

jurisdiction to the full extent of the due process clause. Baker v. Eighth Judicial Dist. Court, 116 

Nev. 527, 531 (2000) (“Nevada’s long-arm statute, NRS 14.065, reaches the limits of due process 

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

set by the United States Constitution.” (citation omitted)). It is well-established that a court’s 

exercise of personal jurisdiction comports with the limits of due process when the defendant 

purposefully establishes “minimum contacts” in the forum state. International Shoe Co. v. 

Washington, 326 U.S. 310, 316 (1945). However, the requisite level of contacts a defendant must 

have to satisfy due process is dependent upon whether the litigation arises out of or relates to the 

defendant’s contacts with the forum state. Burger King Corp. v. Ruzewicz, 471 U.S. 462, 472-473 

(1985). 

Discovery is available to discover facts bearing on issues of jurisdiction. Oppenheimer 

Fund, Inc. v. Sanders, 437 U.S. 340, 350-351 (1978). See also Wells Fargo & Co., 556 F.2d at

430; Marshall, 391 F. Supp. 2d at 882; Dean, 134 F.3d at 1271-72. In this case, since jurisdiction 

is now at issue, the Court should allow Plaintiff leave to discover the scope of Bochenko’s contacts 

with Nevada and with Oron. Because Bochenko is, at the very least, an agent of Oron (and, at the 

most, one of the primary individuals in the infringement scheme), he should be subject to 

jurisdiction anywhere that Oron is subject to jurisdiction. Most relevantly, it seems that Bochenko 

has entered into negotiations and representations with a Nevada-based payment processor on FF 

Magnat Ltd.’s behalf. Exhibit 1. The extent of this information will be of great relevance to 

determining whether the exercise of jurisdiction against Bochenko is appropriate under the Nevada 

Long-Arm Statute. Furthermore, Exhibit 53 contains the phrase “Liberty Media Holdings,” 

suggesting that, contrary to statements made both by Defendant Bochenko and Defendant FF 

Magnat Ltd., at least someone working at Oron was aware of Plaintiff and its presence on Oron’s 

website.

In addition to Bochenko claiming to have had no relationship with FF Magnat Ltd., he also 

claims to have no connection to the activities alleged in this case and to have never used the name 

“Roman Romanov.” However, materials sent to the Plaintiff refute this. Exhibits 6, 7, 9, 12-14, 

23, 35, 41-43. If Defendant Bochenko has perjured himself and can be shown to have worked for 

or in concert with FF Magnat Ltd., as alleged by the Plaintiff, then he is subject to jurisdiction 

where FF Magnat Ltd. is subject to jurisdiction. The agency test, for purposes of personal 

jurisdiction, is predicated upon a showing of the special importance of the subsidiary. The agency 

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

test is satisfied by a showing two things: (1) that the subsidiary performs services that are 

sufficiently important to the foreign corporation that if it did not have a representative to perform 

them, the corporation's own officials would undertake to perform substantially similar services, and 

(2) the parent has a right to control the subsidiary's activities. Bauman v. DaimlerChrysler Corp., 

644 F.3d 909, 919-24 (9th Cir. 2011). In the instant matter, Plaintiff has alleged facts that show 

that during the events that give rise to this dispute, Defendant Bochenko was employed by, acting 

for the benefit of, and engaging contractual relationships on behalf of Oron.com. Accordingly, 

Plaintiff seeks leave to discover the extent of Bochenko’s contacts and contractual relationships 

both with Oron and with Nevada.

Plaintiff simply requests the ability to verify the accuracy of these documents by sending 

subpoenas, document requests, and/or interrogatories to various entities identified in these 

documents: 1) amsVISA, 2) Google’s Gmail services, 3) CCBill, 4) iTunes account records, 5) 

GoDaddy domain records, 6) AlertPay account records, 7) FriendFinder Networks affiliate 

program, 8) WeservIT records regarding forumophilia.com, 9) PayPal records for 

main_max@mail.ru, 10) Dell Computers purchasing records for Maxim Bochenko, and 11) Tulip 

World information on purchases sent to Maxim Bochenko in Florida.

III. CONCLUSION

Plaintiff has stated, with reasonable particularity, the existence of the requisite contacts 

between Defendant Bochenko, the forum state, and Defendant FF Magnat Ltd. to satisfy due 

process standards. In order to determine the full nature, extent, and scope of Defendant 

Bochenko’s contacts with Nevada and with FF Magnat Ltd., Plaintiff should be allowed leave to 

conduct the requisite jurisdictional discovery necessary to prove those contacts. As there is a 

reasonable basis to believe that jurisdictional discovery will reveal that the Defendant Bochenko 

has had additional contact with the forum state, it is proper that Plaintiff be allowed to conduct 

limited discovery on this issue to supplement the record.

For the foregoing reasons, Plaintiff requests that the Court grant them a 60-day period to 

conduct limited jurisdictional discovery, with an additional fourteen (14) days following the close 

of such discovery to submit its brief in opposition to Defendant Bochenko’s Motion to Dismiss.

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Opposition to Defendant Maxim Bochenko’s Motion to Dismiss

Dated: August 7th, 2012

Respectfully Submitted,

 s/Marc J. Randazza

Marc J. Randazza, NV Bar # 12265

Ronald D. Green, NV Bar # 7360

J. Malcolm DeVoy, NV Bar #11950

Randazza Legal Group

6525 W. Warm Springs Rd., Ste. 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

efc@randazza.com

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CERTIFICATE OF SERVICE

I hereby certify that the foregoing document was filed using this Court’s CM/ECF system 

on August 7th, 2012.

Dated: August 7th, 2012

Respectfully Submitted,

 s/Marc J. Randazza

Marc J. Randazza, NV Bar # 12265

Ronald D. Green, NV Bar # 7360

J. Malcolm DeVoy, NV Bar #11950

Randazza Legal Group

6525 W. Warm Springs Rd., Ste. 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

ecf@randazza.com

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