Page 1 - SUPPLEMENTAL DECLARATION OF 

TIMOTHY HASKINS 

Zupancic Rathbone Law Group, P.C. 

4949 Meadows Road, Ste. 600 

Lake Oswego, OR 97035 

Tel: 503-968-8200 Fax: 503-968-8017 

Neil N. Olsen, OSB No. 053378 

nolsen@zrlawgroup.com 

Joseph W. Carlisle, OSB No. 152602 

jcarlisle@zrlawgroup.com 

ZUPANCIC RATHBONE LAW GROUP, P.C. 

4949 Meadows Road, Suite 600 

Lake Oswego, OR 97035 

Telephone: 503-968-8200 

Facsimile: 503-968-8017 

Of Attorneys for Plaintiff 

Copious Creative, Inc. 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

COPIOUS CREATIVE, INC., an Oregon 

corporation, 

Plaintiff, 

vs. 

PATRICK EZELL, an individual, 

Defendant. 

Case No. 3:16-cv-00427-BR

SUPPLEMENTAL DECLARATION OF 

TIMOTHY HASKINS IN SUPPORT OF 

PLAINTIFF COPIOUS CREATIVE, INC.’S 

REPLY TO DEFENDANT’S RESPONSE TO 

COPIOUS’S MOTION FOR TEMPORARY 

RESTRAINING ORDER AND ORDER TO 

SHOW CAUSE WHY PRELIMINARY 

INJUNCTION SHOULD NOT ENTER AND 

MEMORANDUM IN SUPPORT 

 I, Timothy Haskins, hereby declare as follows: 

1. I am the President, sole director on the Board of Directors, and a shareholder in 

Copious Creative, Inc. (“Copious” or the “Company”), and have personal knowledge of the 

matters contained herein. I make this supplemental declaration in support of Plaintiff’s Reply to 

Case 3:16-cv-00427-BR Document 13 Filed 03/14/16 Page 1 of 4
Page 2 - SUPPLEMENTAL DECLARATION OF 

TIMOTHY HASKINS 

Zupancic Rathbone Law Group, P.C. 

4949 Meadows Road, Ste. 600 

Lake Oswego, OR 97035 

Tel: 503-968-8200 Fax: 503-968-8017 

Defendant’s Response to Copious’s Motion for Temporary Restraining Order and Order to Show 

Cause Why Preliminary Injunction Should Not Enter and Memorandum in Support. 

2. Attached hereto as Exhibit 1 is a true and correct copy of Copious’s Security 

Guidelines, which are issued to all company employees. Exhibit 1 reflects that Mr. Ezell signed 

the Security Guidelines on October 1, 2012. 

3. On March 12, 2016, I began the process of closing a company owned Dropbox 

account for David Hughes, a former Copious employee. 

4. When I logged into Mr. Hughes’ former company Dropbox account, I noticed that 

although the account had not been used for some time, Mr. Ezell still had shared access on some 

folders. 

5. The folders were shared originally with Mr. Ezell’s company Dropbox account 

associated with his former company email address, patrick@copiousinc.com. However, Mr. 

Ezell changed the email address associated with the Dropbox account to his personal email 

address, pezell@gmail.com, providing Mr. Ezell with access to the shared folder via his personal 

email address. 

6. In addition, some of the folders shared between Mr. Hughes’ former company 

Dropbox account and Mr. Ezell’s Dropbox account reflect that as of March 12, 2016 they are 

"owned" by Mr. Ezell as they are associated with Mr. Ezell’s personal email address, 

pezell@gmail.com, although they appear to contain company information. 

7. Attached hereto as Exhibits 2 and 3 are true and accurate screenshots from 

Dropbox, dated March 12, 2016, reflecting Mr. Ezell’s shared access to company folders on 

Dropbox and his ownership of some of those folders. Exhibit 2 also reflects that the email 

Case 3:16-cv-00427-BR Document 13 Filed 03/14/16 Page 2 of 4
address associated with Mr. Ezell's former company Dropbox account is now 

pezell@gmail.com, Mr. Ezell's personal email address. 

8. Upon his termination, Mr. Ezell should have returned the company information 

contained in the Dropbox folders he is shown as the "owner" on, as well as the company 

information he had shared access to on Dropbox. He also should have returned his company 

Dropbox account - i.e., he should not have changed the email address associated with that 

Dropbox account to his personal email address. 

9. Shannon Pasco is currently Copious's Creative Director. 

10. On March 2, 2016, Ms. Pasco resigned from Copious. Ms. Pasco is still currently 

employed with Copious, however, with her last day scheduled for March 18, 2016. 

11 . Since the time of her resignation, Ms. Pasco has sought the release of one of 

Copious's clients, Leatherman, from a non-solicitation agreement wherein Leatherman agreed 

not to solicit Copious's employees. 

12. Ms. Pasco has stated that if Copious were to release Leatherman from the nonsolicitation agreement, there would be an opportunity for her to work with Mr. Ezell on that 

account. 

13. Leatherman recently stated that it does not intend to move forward with a project 

it had previously committed to, as the two main company contacts associated with that project 

were David Hughes and Shannon Pasco. 

I HEREBY DECLARE UNDER PENALTY OF PERJURY THAT THE 

FOREGOING IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND 

BELIEF. 

DATED this /!:L day of March, 2016. 

Page 3 - SUPPLEMENT AL DECLARATION OF 

TIMOTHY HASKINS 

Zupancic Rathbone Law Group, P.C. 

4949 Meadows Road, Ste. 600 

Lake Oswego, OR 97035 

Tel: 503-968-8200 Fax: 503-968-8017 

Case 3:16-cv-00427-BR Document 13 Filed 03/14/16 Page 3 of 4
Page 4 - SUPPLEMENTAL DECLARATION OF 

TIMOTHY HASKINS 

Zupancic Rathbone Law Group, P.C. 

4949 Meadows Road, Ste. 600 

Lake Oswego, OR 97035 

Tel: 503-968-8200 Fax: 503-968-8017 

ATTORNEY CERTIFICATE OF SERVICE 

 I hereby certify that I served a true and correct copy of SUPPLEMENTAL 

DECLARATION OF TIMOTHY HASKINS certified by me as such, on the parties below on 

the date and in the manner indicated: 

Dayna J. Christian, OSB No. 97336 

Jeffery Demland, OSB No. 140767 

Immix Law Group PC 

121 SW Salmon St., Suite 1000 

Portland, Oregon 97204 

Tel: (503) 802.5533 

Fax: (503) 802.5351 

E: dayna.christian@immixlaw.com 

E: jeff.demland@immixlaw.com 

Of Attorneys for Defendant Patrick Ezell 

 

 On March 14, 2016 by first class mail and email. 

ZUPANCIC RATHBONE LAW GROUP, P.C. 

/s/ Neil N. Olsen 

Neil N. Olsen, OSB No. 053378 

nolsen@zrlawgroup.com 

Joseph W. Carlisle, OSB No. 152602 

jcarlisle@zrlawgroup.com 

Telephone: 503-968-8200 

Facsimile: 503-968-8017 

Of Attorneys for Plaintiff Copious Creative, Inc. 

 

 

ZR389006

Case 3:16-cv-00427-BR Document 13 Filed 03/14/16 Page 4 of 4