IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

DEAN OBEIDALLAH, 

Plaintiff, 

v. 

ANDREW B. ANGLIN, 

DBA Dai/y Stormer, 

and 

MOONBASE HOLDINGS, LLC, 

DBA Andrew Anglin, 

and 

JOHN DOES NUMBERS 1-10, 

Individuals who also assisted in the 

publication or representation of false 

statements regarding 

Mr. Obeidallah, 

Defendants. 

CASE NO. 2:17-CV-00720-EAS-EPD 

Chief Judge Edmund Sargus 

Magistrate Judge Elizabeth Preston Deavers 

DECLARATION OF ABID R. QURESHI IN SUPPORT OF PLAINTIFF'S RENEWED MOTION FOR 

LEAVE TO CONDUCT LIMITED DISCOVERY IN AID OF SERVICE 

I, Abid R. Qureshi, am an attorney licensed to practice law in the District of Columbia and 

am admitted pro hac vice in the above-captioned case. I am an attorney with Latham & Watkins LLP 

and am counsel of record for Plaintiff Dean Obeidallah. I declare as follows: 

1. Attached hereto as Exhibit 1 is a true and correct copy of the document requests 

that Plaintiff proposes to serve on the following individuals and entities: (1) Greg Anglin; 

(2) Zappitelli CPAs; (3) GoDaddy; (4) Bandwidth; and (5) the U.S. Postal Service. 

Case: 2:17-cv-00720-EAS-EPD Doc #: 23-1 Filed: 12/22/17 Page: 1 of 4 PAGEID #: 225
2. Attached hereto as Exhibit 2 is a true and correct copy of an email sent on or about 

October 13, 2017 by Mr. Obeidallah's counsel to Mr. Marc Randazza. 

3. Attached hereto as Exhibit 3 is a true and correct copy of an email sent on or about 

October 13, 2017 by Mr. Obeidallah's counsel to Defendant Andrew B. Anglin. 

4. Attached hereto as Exhibit 4 is a true and correct copy of an email sent on or about 

December 15, 2017 by Mr. Obeidallah's counsel to Mr. Jay Wolman. 

5. Attached hereto as Exhibit 5 is a true and correct copy of an email sent on or about 

December 15, 2017 by Mr. Obeidallah's counsel to Mr. Mathew Stevenson. 

6. Attached hereto as Exhibit 6 is a true and correct copy of a print out from 

KeepMeUp.com reflecting registration information for the Dai!J Stormels original web domain, 

www.dailystormer.com~ when it was established with registrar GoDaddy on or about March 20, 

2013. 

7. Attached hereto as Exhibit 7 is a true and correct copy of a print out from the Ohio 

Secretary of State's Business Filing Portal regarding Morning Star Ministries USA, Inc. 

8. Attached hereto as Exhibit 8 is a true and correct copy of a print out from the 

Yahoo search engine reflecting contact information for Christian Counselors Group. 

9. Attached hereto as Exhibit 9 is a true and correct copy of a Certificate issued by the 

Ohio Secretary of State reflecting Defendant Moonbase Holdings, LLC's registration of "Andrew 

Anglin" as an Ohio trade name. 

10. Attached hereto as Exhibit 10 is a true and correct excerpted copy of a December 

13, 2016 article originally published by Defendant Anglin on the Dai!J Stormels .COM domain, 

www.dailystormer.com, titled Support the Daify Stormer- With Your Credit Card!. 

Page 2 of4 

Case: 2:17-cv-00720-EAS-EPD Doc #: 23-1 Filed: 12/22/17 Page: 2 of 4 PAGEID #: 226
11. Attached hereto as Exhibit 11 is a true and correct copy of the January 12, 2017 

application by Greg Anglin to establish PO Box 208, Worthington, Ohio 43085 on behalf of 

Defendant Anglin. 

12. Attached hereto as Exhibit 12 is a true and correct copy of an April27, 2017 article 

published on the Daify Storme,;s .COM domain, www.dailystormer.com, tided SPLC Is Suing Anglin! 

Donate Now to Stop These Kikes. 

13. Attached hereto as Exhibit 13 is a true and correct copy of a Certificate issued by 

the Ohio Secretary of State reflecting Defendant Anglin's registration of "Daily Stormer" as an Ohio 

trade name. 

14. Attached hereto as Exhibit 14 is a true and correct copy of a print out from 

Whols.ai reflecting registration information for the Daify Storme,;s .AI web domain, 

www.dailystormer.ai. 

15. Attached hereto as Exhibit 15 is a true and correct copy of a print out from 

Whols.com reflecting registration information for the Daify Storme,;s .RED web domain, 

www .dailystormer.red. 

16. Attached hereto as Exhibit 16 is a true and correct copy of a June 1, 2017 article 

published by Defendant Anglin on the Daify Storme,;s .RED domain, www.dailystormer.red, tided 

Dean Obeidallah, Mastermind Behind Manchester Bombing, Calls on Trump to Declare Whites the Real TeTTOrists. 

17. Attached hereto as Exhibit 17 is a true and correct copy of a Certificate issued by 

the Ohio Secretary of State reflecting the establishment of Defendant Moonbase Holdings, llC as 

an Ohio domestic, for profit limited liability company. 

18. Attached hereto as Exhibit 18 is a true and correct copy of a print out from the 

Franklin County, Ohio Auditor's website reflecting information regarding 5271 Norwich Street, 

Hilliard, OH 43026. 

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Case: 2:17-cv-00720-EAS-EPD Doc #: 23-1 Filed: 12/22/17 Page: 3 of 4 PAGEID #: 227
19. Attached hereto as Exhibit 19 is a true and correct copy of a print out from the 

Franklin County, Ohio Auditor's website reflecting information regarding 5275 Norwich Street, 

Hilliard, OH 43026. 

20. Attached hereto as Exhibit 20 is an true and correct excerpted copy of a print out 

from the Zappitelli CPAs Inc.'s "Contact Us" page.1 

21. Attached hereto as Exhibit 21 is a true and correct excerpted copy of a print out 

from the Zappitelli CP As Inc.'s "Services" page. 

22. Attached hereto as Exhibit 22 is a true and correct copy of a print out from 

GoDaddy.com reflecting registration information for the Daify Stormels original web domain, 

www.dailystormer.com, as of August 15, 2017. 

23. Attached hereto as Exhibit 23 1s a true and correct copy of a print out from 

TheCallRegister.com identifying Bandwidth.com as the "Registrant Company" for Defendant 

Anglin's phone number. 

RespectL bmitte 

( 

555 Eleventh St., NW, Suite 1000 

Washington, D.C. 20004-1304 

Phone: 202.637.2200 

Fx: 202.63 7.2201 

abid.qureshi@lw.com 

Attornry for Plaintiff Dean Obeidallah 

1 In the interest of privacy, Plaintiffs counsel has redacted personal photographs, a phone number, 

and fax number from Exhibit Nos. 20 and 21. 

Page 4 of4 

Case: 2:17-cv-00720-EAS-EPD Doc #: 23-1 Filed: 12/22/17 Page: 4 of 4 PAGEID #: 228